#LEAD ARRANGER SYNDICATED LOAN SERIES#

Obtaining information on its constitution and names of the Board of Directors and its senior management (subject to exclusions for companies listed on a regulated market.Undertaking reasonable measures to ascertain and verify the relevant law the corporate is subject to and.Verifying its registered address and principal place of business.Obtaining and verifying its name and registered number.The 2017 Regulations contain a list of information to be obtained during CDD, for a body corporate this includes: The initial KYC or CDD involves identifying and verifying the identity of the customer as well as assessing the intended nature of the business relationship or transaction. So what are the risk assessments saying? KYC and CDD requirements The FCA has made it clear that these breaches will not be tolerated, given the emphasis placed on adherence over the past decade. 2019 has already seen Standard Chartered Bank fined over £102 million while another international bank was previously fined £896,100 and prevented from accepting deposits from new customers from 147 days for Anti-Money Laundering (AML) systems and controls breaches. With the regulatory spotlight on this area, it is important to adhere to these regulatory obligations throughout the lifecycle of the customer relationship. This guide is non-binding and utilises the same risk-based proportionality approach found in the 2017 Regulations.

In addition there is the FCA's Financial Crime Guide which applies to regulated firms.

When considering their policies, lenders can have regard to the (non-exhaustive) Risk Factor Guidelines issued by the European Supervisory Authorities as well as the sector specific guidance from the Joint Money Laundering Steering Group (JMLSG). Each firm must carry out its own risk assessment by reference to its customers, products or services, transactions, delivery channels and geographical areas of operation. The difficulty or the benefit depending on your perspective, of a risk-based approach is that no one size fits all. Lenders will be aware of the risk-based approach adopted in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the 2017 Regulations) which came into force on 26 June 2017. We will also look at the practical impact GDPR has had on the CDD process over the last year. In this article we examine how the UK's anti-money laundering regime impacts initial Know Your Customer (KYC) and ongoing Customer Due Diligence (CDD) requirements in the syndicated lending market.

#LEAD ARRANGER SYNDICATED LOAN SERIES#

CDD and AML monitoring in syndicated lending Part two in a series of six highlighting some of the key legal issues that can arise throughout the life of a syndicated loan facility.

Lead arranger syndicated loan