ComplianceCaptain
Registered
I have had a strange situation where I am looking to gauge common CB practice.
I have a client that refused a UKAS observation audit and then refused to engage with us. As a result we have initiated the derecognition process, but are unable to derec as the client has already transferred to another CB. IAF MD 2 states that when transfers occur the receiving CB must notify the previous CB to inform them of the fact. This hasn't occurred. If it had we would have notified them we were about to derecognise them and informed them of them breaching the T&Cs. Not only did they CB not contact us, I assume that they obtained the previous report and corrective action plan, directly from the client.
So the question is - do you do your due diligence when onboading a client and check that they haven't been dumped by a previous CB due to not fulfilling the requirements to certify?
I have a client that refused a UKAS observation audit and then refused to engage with us. As a result we have initiated the derecognition process, but are unable to derec as the client has already transferred to another CB. IAF MD 2 states that when transfers occur the receiving CB must notify the previous CB to inform them of the fact. This hasn't occurred. If it had we would have notified them we were about to derecognise them and informed them of them breaching the T&Cs. Not only did they CB not contact us, I assume that they obtained the previous report and corrective action plan, directly from the client.
So the question is - do you do your due diligence when onboading a client and check that they haven't been dumped by a previous CB due to not fulfilling the requirements to certify?