Maintaining Customer Identity Details: A Key Requirement for Financial Institutions

The fight against money laundering and terrorism financing requires financial institutions to maintain a high level of transparency in their customer identity details. As per the regulations outlined by the Wwft (Wet ter voorkoming van witwassen en financiering van terrorisme), institutions are required to identify and record the Ultimate Beneficial Owner (UBO) of a customer.

Identifying and Recording the Ultimate Beneficial Owner

To comply with these regulations, financial institutions must:

• Examine the customer’s ownership and control structure: This involves analyzing the complex structures used by customers to understand their tax motives.
• Designate senior management as the UBO in certain cases: In situations where the UBO is not a natural person, senior management may be designated as the UBO.

Maintaining a Central Register of Customer Identity Details

Institutions must maintain a central register of customer identity details, including data recorded pursuant to Section 33 of the Wwft. The central register should be set up in such a way that it can be searched by:

• Name: Institutions must allow for searching by name to ensure that UBOs and customers can be easily identified.
• Number or code key: A search functionality by number or code key is also required, allowing institutions to quickly retrieve information.

Implementation of Central Register Requirements

While the text does not specify which banks and bank branches are required to maintain this central register, it is likely that all institutions subject to the Wwft (including banks, credit unions, and other financial institutions) must implement these requirements.