The FCA states that it recognises the need to balance financial crime checks with getting money to businesses in need. Therefore existing customers, on which customer due diligence (CDD) has already been conducted, do not need additional checks unless other red flags of money laundering are identified.

For new customers, CDD must still be applied, but firms may make the decision to apply simplified due diligence where it deems the customers low risk. The FCA also pointed to alternative verification methods outlined in its recent “dear CEO” letter.