As an international agency/branch of a foreign bank, we perform transactions for non-account holders. (No cash involved, mainly wires/SWIFT) Transactions could be one time or perhaps once a month.
Since they do not have an account relationship as defined in the CIP rules, are we okay? Or should there still be some sort of due diligence.
We obtain their ID information at the time of transaction.
Any advice / guidance would be appreciated. Thank you.