Text for CQS CPMS Policy
CQS Policy: Enhanced Due Diligence: High-Risk Matters and Clients (update)
Purchase this policy: Anti-Money Laundering Policy
- Change date
- 13/07/2026
- Word count
- 1,312
- Deployment measure
- 7/10
Rationale
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 have overhauled EDD triggers, introducing mandatory Sterling thresholds and specific digital asset controls while replacing the old High-Risk Third Country framework. This draft updates reflects these new statutory triggers, updated compliance rules, and risk classifications to ensure full regulatory alignment
We must carry out ‘enhanced due diligence’ (EDD) in circumstances where a transaction or client relationship presents a heightened risk of money laundering or terrorist financing. Following the coming into
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