Examination Timing: 00H00M01S
Emma Johnson, a solicitor, acts for Neville's Digital Marketing Company Limited, a private company and a regular, albeit sporadic, client. The last engagement was in 2007, and Emma conducted all required due diligence checks at that time with no concerns. The company now seeks to instruct Emma on a private equity matter worth £50,000, and there is no urgency.
What should Emma do?
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According to Regulation 7(2) of the Money Laundering Regulations 2007, solicitors must apply Customer Due Diligence (CDD) measures at appropriate times and on a risk-sensitive basis for existing clients. The Law Society's Practice Note on AML suggests performing CDD for clients with a gap of three years or more between instructions. As it has been over three years since Emma last acted for Neville's Digital Marketing Company Limited, standard due diligence is required before proceeding with the new transaction and ongoing monitoring should be conducted.
Key Point: This question assesses the requirement for ongoing customer due diligence for existing clients after significant time gaps, as per the Money Laundering Regulations 2007. Solicitors must stay current with regulatory requirements to ensure compliance.
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