{"id":10719,"date":"2025-11-25T10:30:14","date_gmt":"2025-11-25T10:30:14","guid":{"rendered":"https:\/\/www.amlcc.com\/?p=10719"},"modified":"2025-11-25T10:30:47","modified_gmt":"2025-11-25T10:30:47","slug":"cdd-requirements-for-payroll-and-bookkeeping-firms","status":"publish","type":"post","link":"https:\/\/www.amlcc.com\/mf\/cdd-requirements-for-payroll-and-bookkeeping-firms\/","title":{"rendered":"CDD requirements for payroll and bookkeeping firms"},"content":{"rendered":"\n

CDD requirements for payroll and bookkeeping firms<\/h1>\n\n\n
\"Richard<\/div>
Richard Simms<\/span>

Director and Founder of AMLCC and AMLCC Consult<\/h3><\/div><\/div><\/div><\/div>\n\n\n
\"CDD<\/figure><\/div><\/div>\n\n\n\n
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Customer due diligence (CDD) is triggered the moment a business relationship starts. For payroll and bookkeeping services, that means before you carry out any work, handle any client money or access client data.<\/p>\n\n\n\n

CDD is your way of confirming who the client is, understanding the purpose of the relationship and assessing the risk they pose. Without completing the full process, you can\u2019t show that you\u2019ve met your legal duties under Regulation 27<\/a> of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs).<\/p>\n\n\n\n

When does a business relationship begin?<\/strong><\/h2>\n\n\n\n

The law defines a business relationship in Regulation 4<\/a> of the MLRs as:<\/p>\n\n\n\n

\u201ca business, professional or commercial relationship between a relevant person and a customer, which\u2014 (a) arises out of the business of the relevant person, and (b) is expected by the relevant person, at the time when contact is established, to have an element of duration.\u201d<\/p>\n\n\n\n

This means more than completing digital AML checks<\/a>. You should:<\/p>\n\n\n\n