3. Consolidated AML/CFT policies and procedures (paras. 69-76)
69. A bank should ensure it understands the extent to which AML/CFT legislation allows it to rely on the procedures undertaken by other banks (for example within the same group) when business is being referred. A bank should not rely on introducers that are subject to standards that are less strict than those governing the bank's own AML/CFT procedures. This will entail banks monitoring and evaluating the AML/CFT standards in place in the jurisdiction of the referring bank. A bank may rely on an introducer that is part of the same financial group and could consider placing a higher level of reliance on the information provided by this introducer, provided this introducer is subject to the same standards as the bank, and the application of these requirements is supervised at the group level. A bank taking this approach should ensure, however, that it obtains customer information from the referring bank (as further detailed in Annex 1), as this information may be required to be reported to FIUs in the event that a transaction involving the referred customer is determined to be suspicious.
70. Relevant information should be accessible by the banking group's head office for the purpose of enforcing group AML/CFT policies and procedures. Each office of the banking group should be in a position to comply with minimum AML/CFT and accessibility policies and procedures applied by the head office and defined consistently with the Committee guidelines.