 
          When to Conduct CDD?
        
        
          •
        
        
          Before or during the course of establishing the
        
        
          business relationship or conducting an occasional
        
        
          transaction
        
        
          •
        
        
          greater than $15,000 (or a lesser amount determined
        
        
          by entity); or
        
        
          •
        
        
          Wire transfers
        
        
          •
        
        
          Where the ML/TF risks are effectively managed
        
        
          •
        
        
          Essential not to interrupt normal conduct of business
        
        
          (e.g. non face-to-face business, time sensitive
        
        
          securities transactions)