What does the deemed compliance provision actually require?
Explains the three conditions (reasonable steps, full documentation, SMR consideration) that establish deemed compliance when the counterparty will not cooperate with initial CDD.
Where the party you aren't acting for doesn't cooperate, you're treated as having complied with your initial CDD obligation on that party if all three of the following are satisfied: All reasonable steps taken — you've taken all reasonable steps to establish the other party's identity, including through reliance arrangements where possible (e.g.
For the full answer, see What are the critical limits on using Deemed Compliance provision?.
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