Zenith Bank (UK) Limited

Limits on what they may do

• Voluntary Application for Imposition of Requirements

  Requirements: 1) The Firm must not onboard new customers in respect of any business of the Firm, except with the prior written consent of the FCA or under the conditions set out in 2. 2) The conditions under which the Firm may onboard new customers are: i) for each new customer, the Firm must demonstrate that it has undertaken a full and effective financial crime risk assessment in line with its policies and procedures, and that all necessary due diligence has been appropriately completed, documented and is considered within the Firm's risk appetite and regulatory obligations; ii) Each new customer onboarding has been reviewed by a suitably qualified external consultant to assess that the underlying due diligence is adequate and in line with applicable regulations, have due regard to relevant industry guidance, and policies and procedures of the Firm; and iii) after the Firm has addressed any deficiencies identified by the consultant with the onboarding of the new client and the consultant has verified that the deficiencies have been addressed. 3) The Firm must provide regular updates to the FCA on the progress of its remediation and make available upon request evidence of the financial crime risk assessments undertaken for each new customer onboarded during the period in which this requirement is effective. Each update submitted to the FCA must be reviewed and approved by an appropriate Senior Management Function holder.