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The latest paragraphs for you to consider including in your AML Update Service.

Text for AML Update Service

AML Update: Sanctions - Giftors

Purchase this policy: Sanctions Policy

Change date
20/10/2025
Word count
118
Deployment measure
8/10
Rationale

Draft wording should confirm that giftors must undergo the same due diligence as clients to avoid indirect links to Designated Persons (DPs), and that no funds, including payments on account, may be accepted before due diligence is complete, in line with sanctions requirements.

In relation to conveyancing transactions, we must not only scrutinise direct clients but also those contributing to a transaction such as giftors. Giftors in conveyancing transactions should undergo the same …

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