In December 2016, the Central Bank published its first
Anti-Money Laundering Bulletin. These bulletins are intended to
provide guidance and feedback to firms in complying with their
anti-money laundering / countering the financing of terrorism
("AML/CFT") obligations. The first bulletin covers the
topic of third party reliance.
A firm may rely on relevant third parties to complete certain
customer due diligence ("CDD") measures, provided that
there is a contractual arrangement in place with the third party
and the third party undertakes to provide to the firm any CDD
documents or information obtained as soon as practicable upon
request.
In the context of investment funds, third party reliance
arrangements between the fund or its administrator and a relevant
third party that acts as a fund distributor or a nominee for
underlying investors are common. In order to ensure that these
arrangements meet the Central Bank's expectations, a fund and
its administrator should
