Question to the HM Treasury:

To ask Her Majesty's Government, further to the Written Answer by Lord Young of Cookham on 8 July (HL16623), whether the requirement for business to “take a proportionate approach” and create “their own policies based on their assessment of risk” means that customer due diligence checks by businesses and banks for existing customers who have not given any cause for concern are optional.

The Money Laundering Regulations 2017 are clear that all relevant persons (such as banks) must apply customer due diligence (CDD) measures if the person establishes a business relationship (regulation 27). Whilst CDD measures include conducting ongoing monitoring of a business relationship, as outlined in my previous answer, the extent of the measures taken must reflect the risk assessment carried out by the relevant person under regulation 18(1) and its assessment of the level of risk arising in any particular case. Therefore, if a customer is deemed low risk, the extent of ongoing CDD measures would be tailored to that risk assessment and minimum monitoring would be expected.