3rd EU Money Laundering Directive brings changes. Part 2

It has already been discussed that the Third EU Money Laundering Directive  effective from December 15, 2007 brought some essential changes. Now, firms need to have a risk assessment in place, to conduct their client due diligence on the basis of this risk assessment, and to monitor their clients – both new and existing.

In accordance with the Third EU Money Laundering Directive, monitoring existing clients is a continuous requirement for firms. However, it should be noted that the new regulation does not require immediate request of identification information from firms’ well-established clients. Well-known clients are to submit only limited extra evidence of their identity, which is permitted in copies of some bank correspondence or copies of a tax return.

It is worth noting that anonymous accounts and anonymous passbooks will no loger be allowed to be kept. The owners or beneficiaries of existing anonymous accounts may become the subject od customer due diligence.

As regards record keeping, copies or references of evidence are to be kept for 5 years after the end of the relationship. Also, there must be systems for full and rapid response to enquiries for authorities like the Financial Intelligence Unit (FIU).

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