15) Should a regulated entity seek the consent of the designated authority to do all future business with a customer whose transaction has been the subject of a request for appropriate consent from the designated authority?

It is not necessary to seek the consent of the designated authority to conduct another type of transaction with that customer where the funds involved appear to be from a legitimate source. This is because a transaction would only constitute a prohibited act if it involves the proceeds of criminal conduct.

The designated authority is not in a position to provide a general “blanket” consent to the conduct of all future transactions with a particular customer. The requirement for consent under sections 92 and 93 pre-suppose that consent is being sought in relation to a particular activity or transaction.

Nonetheless, where a regulated entity becomes concerned about the lawfulness of funds held on behalf of a customer, any further action/s with these funds would necessitate the consent of the designated authority. This means that in relation to each transaction that involves “suspicious funds” the consent of the designated authority must first be sought and obtained.