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Makes available the latest paragraphs for you to consider including in your CQS CPMS Policy.
text for CQS CPMS Policy:
CQS Policy: Controls Implemented by this Firm - Update
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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