Prior to 18 May, reporting entities conducting customer due diligence (CDD) on trusts were required to verify source of wealth (SoW) and source of funds (SoF) by reliable and independent means - regardless of the trust's risk profile. This was a blanket requirement that applied broadly across trust customers.
The Financial Markets Authority and Department of Internal Affairs released updated guidance on outsourcing Customer Due Diligence that reiterates a very important message for anyone using third parties to manage it.
