Thanks, Jim. I appreciate there is no difference between £1 and £1k as such - the judgment is interesting though as it discusses whether or not a "one-off, short-lived" transaction has the necessary "element of duration" (reg 4(1)(b)) to trigger the legal obligation for CDD under the regs - making the point that the regulations themselves define and discuss such 'occasional transactions' separately with a 15k EUR de minimis under reg 27(2), the clear implication being that a business relationship with the necessary 'element of duration' must involve more than an occasional transaction. The 2017 regulations are stricter but they are still structured in the same way in this regard.
Can I ask then, how would you typically go about CDD for an individual who approaches you online and asks for such one-off advice? If a client provides me with a certified copy of a passport and I verify that online then all that proves is the passport is a genuine one, not that the person you are emailing is the person on the passport. If it's not practical to meet that person, and you wish to correspond by email rather than their verified postal address (let's say they live overseas and postal correspondence is slow, expensive and impractical), then I struggle to see how you can properly identify the client unless, perhaps, you have a video conference call. So I'm interested to know where I would stand legally if that were not possible for whatever reason.