IEIM401870 | Financial Accounts: Excluded Accounts: Escrow Accounts: Undesignated and Designated Accounts

Financial Accounts: Excluded Accounts: Escrow Accounts: Undesignated and Designated Accounts

Undesignated Accounts

Where a financial account (held by a non-financial intermediary such as a solicitor) does not meet the conditions in IEIM401860, but is an account, holding on a pooled basis, and the funds of underlying clients of the non-financial intermediary where:

• the only person listed or identified on the financial account with the Financial Institution is the non-financial intermediary; and

• the non-financial intermediary is not required to disclose or pass their underlying client or clients’ information to the Financial Institution for the purposes of AML/KYC or other regulatory requirements

then, providing both these conditions are met, the Financial Institution is only required to undertake the due diligence procedures in respect of the non-financial intermediary.

Designated Accounts

A designated client account is an account held with a Financial Institution, operated by a non-financial intermediary where the underlying client or clients of the intermediary are listed or can be identified by the Financial Institution. Where the underlying client is identified as a Reportable Person [see IEIM403440] the Financial Institution should report the relevant information about the account.