• the other regulated person must consent to being relied on, and must then keep relevant records for five years;
• even if you do rely upon another person, you remain liable for any failure to meet CDD standards; and
• the categories of regulated persons on whom you can rely is relatively limited (the list is in Reg 17(2)). Note that reliance can be placed on any such persons when they are carrying on business in another EU state, provided they are subject to mandatory professional registration recognised by law and supervised under the Money Laundering Directive.

Reliance is, of course, totally different from using someone else to carry out CDD (eg electronic verification service providers). Within the legal sector, the main beneficiaries of Reg 17 are likely to be law firms with branches in different countries, when one client uses the services of several of those offices. Previously, the client had to be identified under the local laws of each jurisdiction, but now firms will be able to rely on identification carried on by other offices provided it meets the Directive standards. © Practical Lawyer