What does client screening mean?

If the services required from us fall under the Wwft, we are required by law to conduct a client screening. The extent of the investigation depends on the extent of the risk of money laundering or terrorist financing. This risk is determined in advance on the basis of various factors laid down in the law, by the government and by supervisory authorities. Examples are: the nature of the services, geographical risk factors, the industry in which the client operates and the way in which the transaction is financed. We are not permitted to render any substantive services until the client screening has been completed in full and in accordance with the Wwft. The Wwft prohibits us from accepting the assignment if the client screening cannot be completed in full and in accordance with the Wwft. In that case, an existing business relationship must also be terminated.

The client screening means that we must research at least:

If the client is a natural person

  • the client’s identity and any representative;
  • the purpose and intended nature of the business relationship;
  • the representative authority of the person acting on behalf of the client;
  • whether the client is acting for himself or herself or for someone else;
  • whether the client is a politically exposed person (a ‘PEP’);
  • the origin of the funds (e.g. money) used in the transaction.

In most cases, the investigation into the origin of the funds does not have to be completed before we are permitted to accept the assignment.

If the client is a legal entity

  • who the ‘ultimate beneficial owner’ (‘UBO’) or pseudo-UBO is;
  • the client’s identity, any representative and the UBO or the pseudo‑UBO;
  • the purpose and intended nature of the business relationship;
  • the ownership and control structure of the legal entity;
  • the representative authority of the person acting on behalf of the client;
  • whether the client is acting for himself or herself or for someone else;
  • whether the UBO or the pseudo-UBO is a politically exposed person (a ‘PEP’);
  • the origin of the funds (e.g. money) used in the transaction.

In most cases, the investigation into the origin of the funds does not have to be completed before we are permitted to accept the assignment.

Enhanced client screening

Sometimes we are obliged to take additional measures, in line with the higher risks that have emerged. Enhanced client screening, for example, is mandatory if:

  • the client (natural person) or representative (such as a director) is not physically present for identification purposes;
  • the client, the UBO or the pseudo-UBO is a politically exposed person (a ‘PEP’); and/or
  • there is involvement in a country with a ‘high risk’. This is apparent from the various lists that we have to check.

A combination of factors can also lead to a high risk, and therefore to a mandatory enhanced client screening. Such factors include, for example, the industry in which the client operates, the way in which a purchase price is determined, the way in which the financing takes place and a structure that seems complex given the business activities.

COVID-19 mededeling

Ook in deze bijzondere tijden staan wij voor u klaar. Wij hebben maatregelen genomen zodat wij onze diensten aan u kunnen blijven verlenen. Neem dus gerust contact met ons op. U kunt op ons rekenen.

Als het voor de dienstverlening noodzakelijk is dat u bij ons op kantoor komt, dan ontvangt u een protocol met maatregelen voor uw en onze veiligheid.

Voor ondernemers hebben onze specialisten documenten opgesteld om de onderneming én de ondernemer te helpen in deze bijzondere tijden (zie onderaan deze mededeling).

COVID-19 notice

We are also there for you during these special times. We have taken measures so that we can continue to provide our services to you. Feel free to contact us. You can count on us.

If it is necessary for our services that you come to our office, you will receive a protocol with measures for your and our safety.

For entrepreneurs, our specialists have drawn up a document with tips to help both the company and the entrepreneur to manage insolvency risks due to the corona crisis.

Tips voor het ondernemen in bijzondere tijden: NOW, WHOA, digitaal vergaderen (NL)