Comprehensive changes needed for some businesses to fully comply with Enhanced and Simplified Due Diligence Measures and Exemptions
Several regulated businesses will need to make comprehensive changes to their systems and controls to fully comply with the requirements for Enhanced Customer Due Diligence, Simplified Customer Due Diligence and Exemptions, following our recent examination.
In total, we examined ten businesses which included deposit-taking businesses, fund services businesses, investment businesses, and trust company businesses. Two of the businesses were fully compliant, whereas we identified 22 findings when we reviewed the other eight businesses, five of which were not part of the examination’s scope.
We also issued a questionnaire to a further 20 businesses across all sectors and considered their responses alongside our examination findings.
The findings highlight a range of statutory obligations and regulatory requirements that were either not complied with or were only partially complied with.
The following chart shows the breakdown of the 22 findings which were within the scope of our examination. The ‘out of scope’ findings related to measures to prevent and detect money laundering and terrorist financing.

Webinar – 13 October 2021
On Wednesday 13 October, Amanda Reilly, our Head of Examinations, Sarah Valerkou, Senior Manager in our Supervision Examination Unit and Hamish Armstrong, Chief Adviser – Financial Crime, will host a webinar taking a more detailed look at the findings.