What are practical workflow when the buyer won't cooperate with CDD?
Follow a clear set of recorded steps when the buyer will not cooperate with CDD.
- Direct request first — at offer acceptance, send the buyer your onboarding/verification link
- Escalate via the buyer's conveyancer or solicitor — same request, with reliance language
- Attempt reliance — request the conveyancer's verified KYC under case-by-case or ongoing reliance
- Document everything — every attempt, every refusal, dated and saved in the file
- Risk-assess the refusal — pure non-response with no other red flags is different from refusal accompanied by suspicious indicators; document the assessment either way
- Lodge an SMR if reasonable suspicion is triggered — within 3 business days; do not tip off
- Record the deemed compliance determination — at the file level, with reference to the three criteria
- Maintain ongoing CDD — deemed compliance closes the initial CDD gap; the ongoing CDD obligation runs until settlement, so re-assess if new info changes the picture
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