Outsourcing of administration duties does not absolve the manager of a CIS from its obligations as a reporting entity under the Act. It is sensible to consider the 'agent' who is contracted to undertake administration as an extension of the reporting entity. Irrespective of whether an 'agent' is carrying out any functions on its behalf, the reporting entity must still complete a risk assessment and AML/CFT programme under the Act. The risk assessment should take into consideration any risks that are posed by the outsourcing of administration functions. The AML/CFT Programme must consider policies and procedures to manage any identified risks that outsourcing may present.
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