Gatekeepers and professional intermediaries play an important role in financial services, but they can also introduce significant AML and reputational risk. This session explores how firms should understand, assess and manage those relationships in practice.

In this session, Angela Mele of RiskPass examined the different roles gatekeepers can play across client structures, including the distinction between gatekeepers, DNFBPs, professional intermediaries and introducers — and why those distinctions matter when determining responsibility for CDD and ongoing compliance.

The discussion also focused on third-party reliance. While firms may rely on another regulated party to perform certain elements of CDD, ultimate responsibility remains with the relying firm. This makes it important to understand who you are relying on, assess the risks associated with that relationship and ensure information and supporting documentation can be obtained when required.

In this session we covered:

• What defines a gatekeeper in practice
• The differences between gatekeepers, DNFBPs, introducers and professional intermediaries
• How gatekeepers operate across legal, corporate and financial structures
• The AML obligations that apply to gatekeepers
• When and how firms can rely on third parties for elements of CDD
• Why responsibility for CDD remains with the relying firm
• Cayman’s Eligible Introducer framework and practical reliance considerations
• How to risk-rate gatekeepers using factors such as jurisdiction, regulated status, services, reputation and track record
• Red flags that may indicate reliance should be suspended or stopped
• The importance of testing introducer relationships, monitoring concentration risk and maintaining appropriate governance