Banks as designated persons under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (“the Act”) are obliged to conduct ongoing monitoring of their customers and to keep their information/documentation up to date. This is in line with the risk-based approach allowing a designated person to apply appropriate measures. It also recognises that customer profiles change over time, as does the nature of business relationships. It allows designated persons to monitor the business relationship and mitigate the risk of money laundering or terrorist financing.
The criteria by which a bank will make a decision that a customer is subject to Section 37 of the Act are set out in Section 37(10) which define what constitutes a politically exposed person, an immediate family member of a politically exposed person or a close associate of a politically person.