Beruflich Dokumente
Kultur Dokumente
and AML
IN RELATION TO THE FOURTH AML DIRECTIVE
Contents
2
Understanding the nature and purpose of an account holder
and monitoring accounts to protect financial integrity
Collection of KYC information
CRS declaration forms to use for AML purposes as well
Monitoring accounts use of existing AML systems for the
purpose of CRS
Knowing the protocol of what makes a beneficial owner under
AML rules
Usage of the central UBO registry
Setting up the beneficial ownership chain
What changes are being made to the disclosure of 29.11.2016
3
Collection of KYC information in case of a private person#1
Check signature from passport & given signatures and passport security
elements (prado.consilium.europa.eu / IdenTT).
29.11.2016
UBO REGISTRY 11
All countries shall create a registry on UBOs, e.g. in company registry.
Institutions may not rely solely (=at all) on the registry.
Institutions might be asked to pay for the registry information new
form of tax can be levied on financial institutions, as they have to get data
from the registry they cannot use.
It must be web based, as timely access shall be granted.
Anybody shall access part of the data, who demonstrates a legitimate
interest impossible to check.
Filling the registry with data new form of taxation on companies.
Most complex structure institutions currently have no information on their
UBOs, due to very complex structures, even UBOs may not know, that
they are UBOs at some companies. 29.11.2016
12
What changes are being made to the disclosure/collection of information?
Disclosure ruleset between FIUs are created almost same as if they were
domestic authorities.
Steve Maraboli
29.11.2016