Text for CQS CPMS Policy
CQS Policy: Controls Implemented by this Firm - Update
Purchase this policy: Sanctions Policy
- Change date
- 24/07/2025
- 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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