The most significant changes are:

1. New requirement for reporting entities dealing with companies, limited partnerships, and overseas limited partnerships to establish and verify the existence of nominee directors, nominee shareholders and nominee general partners as part of customer due diligence (CDD). If any exist, the reporting entity must conduct enhanced due diligence (EDD) on the customer.
   Note: there is a compliance transitional period that applies to parts of this new regulation. Read the Strategi Compliance guidance note to understand what this transitional period is and how it applies to your business.
2. Increase of the default audit period for most reporting entities from two years to three years (with a possibility of a four-year time-period upon notification by the relevant AML/CFT supervisor). We strongly recommend that you don’t automatically move your compulsory audit out to three years as doing so may increase your business risk. For more information read our article Interpreting the audit timeframe extension as well as the Guidance Note. If you’re not sure what’s best for your business talk to us and we can help you work out when it’s appropriate to move to a three year audit cycle. 
3. Redefinition of the term ‘related’ to apply to entities that are not body corporates – resulting in an expanded ‘related entity’ exemption, and the ability for related limited partnerships to form DGBs.
4. New exemptions and limited exemptions from AML/CFT obligations for entities providing certain relevant services, such as a designated non-financial business or profession (DNFBP) making low risk transactions, parties subject to a Commissioner of Police’s order/production order, and court appointed liquidators.
5.  Delayed timing for real estate agents conducting CDD in relation to commercial lease transactions.

The Strategi Compliance guidance note provides a full summary of the changes plus guidance on what each key change means in practice. Some of these changes are very technical in nature so don’t hesitate to get in touch with any questions.