Teal tales #1 - Consent for missing CDD information

We get many calls from firms who have unusual compliance queries. They are my favourite calls! In this series, I will share some of the issues, and solutions. Today’s tale is a common one, and the issue it raises is a common misconception. In fact, we had 2 calls about this on the same day, with similar issues. “We’re ready to complete, there is a third-party funder, we’ve asked for source of funds information, but it’s not forthcoming. Can I get consent?” The answer to that question will depend on the facts of each case, and whether there is a suspicion of money laundering. Quite often in these situations I ask the firm what they are suspicious about, they will say, the fact the clients are

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