6.2.1 Establishment of a Business Relationship

Effective from 13/7/2023

FIs establish a Business Relationship with a customer when they perform any act for, on behalf of, or at the direction or request of the customer, with the anticipation that it will be of an ongoing or recurring nature, whether permanent or temporary. Such acts may include, but are not limited to:

•	Assigning an account number or opening an account in the customer’s name;
•	Effecting any transaction in the customer’s name or on their behalf, or at the customer’s direction or request for the benefit of someone else;
•	Providing any form of tangible or intangible product or service (including but not limited to granting credits, guarantees, or other forms of value) to or on behalf of the customer, or at the customer’s direction or request for the benefit of someone else;
•	Signing any form of contract, agreement, letter of intent, memorandum of understanding, or other document with the customer in relation to the performance of a transaction or series of transactions, or to the provision of any form of tangible or intangible product or service as described above;
•	Accepting any form of compensation or remuneration (including a promise of future payment) for the provision of tangible or intangible products or services, as described above, from or on behalf of the customer;
•	Receiving funds or proceeds of any kind (including those held on a fiduciary basis, for safekeeping, or in escrow) from or on behalf of the customer, whether for their account or for the benefit of someone else;
•	Any other act performed by FIs in the course of conducting their ordinary business, when done on behalf of, or at the request or direction of, a customer.

In such cases, and other than in the exceptional circumstances described below (see Section 6.2.3, Exceptional Circumstances), FIs are required to undertake appropriate risk-based CDD measures (see Section 6.3, Customer Due Diligence (CDD) Measures, Section 6.4, Enhanced Due Diligence (EDD) Measures, and Section 6.5, Simplified Due Diligence (SDD) Measures for further guidance).

In addition, CDD also needs to be conducted when

•	there is a ML/FT suspicion (see Section 7.2, Identification of Suspicious Transactions);
•	there are doubts about the veracity or adequacy of identification data previously obtained with regard to the customer.

Among other things, the CDD measures should include verifying the identity of the customer as well as the Beneficial Owners, beneficiaries, and controlling persons, and understanding the nature of their business and the purpose of the Business Relationship.