If a lender does credit checks, does that satisfy AML requirements?
No, credit checks assess ability to repay and serve a different purpose; they do not satisfy AML CDD obligations and cannot be relied on by real estate agents or conveyancers.
No. Credit checks and AML CDD serve different purposes:
- A credit check assesses the customer's ability to repay - their credit history, defaults, current credit exposure.
- An AML CDD assesses identity, beneficial ownership, PEP/sanctions exposure, and money laundering risk.
A lender performing a credit check is performing their own credit risk assessment. It doesn't discharge any other party's AML/CTF obligations. A real estate agent or conveyancer cannot rely on the lender's credit check to satisfy their own CDD requirements - they must perform their own checks, or formally rely on another reporting entity's CDD under a written reliance arrangement (see §5 of this file).
For the customer-facing summary, see HubSpot KB: https://knowledge.easyaml.com/common-customer-due-diligence-questions
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