According to MLR 2017, when must a relevant person carry out Customer Due Diligence (CDD) measures?

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The requirement for a relevant person to carry out Customer Due Diligence (CDD) measures when establishing a business relationship is grounded in the objectives of the Money Laundering Regulations (MLR) 2017, which are designed to prevent criminal activity and ensure that businesses know their clients. Implementing CDD at the start of a business relationship allows for the assessment of risks associated with money laundering and terrorist financing from the outset.

By performing CDD measures, businesses can gather necessary information about clients and their financial situations, verify identities, and understand the nature of the relationship. This proactive approach helps to mitigate risks and ensures compliance with legal obligations.

Other options do not align with the MLR's proactive stance on CDD. Carrying out CDD only at the end of a business relationship would be insufficient, as it could lead to exposure to risks that could have been managed or mitigated earlier. Conducting CDD only upon client request undermines the responsibility of the business to ensure it is not facilitating financial crime, and limiting it to audits only would be too sporadic to effectively monitor and manage ongoing risks.

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