AML/CFTR 3.3.4 Products with fictitious or false names or no names

(1) A financial institution must not permit any of its products to be used if the product:
(a) uses a fictitious or false name for a customer; or
(b) does not identify the customer's name.
(2) Subrule (1) does not prevent the financial institution from providing a level of privacy to the customer within the financial institution itself by not including the customer's name or details on the account name or customer file if:
(a) records of the customer's details are kept in a more secure environment in the firm itself; and
(b) the records are available to the financial institution's senior management and MLRO, and to the Regulator and FIU.
(3) Without limiting subrule (1), if the financial institution has numbered accounts, the financial institution must maintain them in a way that enables it to fully comply with the AML/CFT Law and these rules.

Example for subrule (3)

The financial institution could properly identify the customer for an account in accordance with the AML/CFT Law and these rules and make the customer identification records available to the MLRO, other appropriate officers and employees, the Regulator and the FIU.
Derived by QFCRA RM/2019-8 (as from 1st February 2020)