About this form
Form C is the enhanced customer due diligence record, used where the risk assessment on Form B has concluded that a higher-risk situation exists. It carries an obligation no other form in the set does: the Compliance Officer must approve before the business relationship is established or continued.
When you need it
- The risk assessment has identified a higher-risk situation under the guide’s Part 6.
- A politically exposed person is involved.
- Screening or the red-flag checklist has surfaced something requiring more than standard measures.
How to complete it
- Complete standard due diligence first — Form C supplements it rather than replacing it.
- Record the additional measures actually taken, including any additional verification of source of funds or wealth.
- Obtain the Compliance Officer’s PRIOR approval. Approval after the fact does not satisfy the requirement.
- Where an unrepresented counterparty is also involved and the situation is higher risk, complete Form U6 for them as well.
- Document the reasoning, not just the conclusion.
Common mistakes
- Proceeding on the basis that approval will be given, and seeking it afterwards.
- Treating Form C as a replacement for the standard forms.
- Recording enhanced measures generically rather than describing what was actually done.
- Completing Form C for the client but overlooking Form U6 for a higher-risk unrepresented counterparty.
Legal basis
Published by CEA as an annex to the Guide on the Estate Agents (Prevention of Money Laundering and Financing of Terrorism) Regulations 2021. Read the issuer’s guidance.
Questions
- Who approves enhanced due diligence?
- The Compliance Officer, and the approval must be obtained before the relationship is established or continued — not retrospectively.
- What makes a situation higher risk?
- The guide sets this out in Part 6. Because the criteria are the regulator’s and may be revised, check CEA’s current guide rather than relying on a list reproduced elsewhere.
- When must it be completed?
- All due diligence must be complete BEFORE the client enters into any agreement — before an Option to Purchase is issued or exercised, and before a Tenancy Agreement is signed.