Guidelines on due diligence obligations with respect to clients and their beneficial owners

DOC-2019-16 sets out the due diligence obligations with regard to clients and their beneficial owners, as provided by Articles L. 561-4-1 and following of the Monetary and Financial Code, taking account of the essential contributions of the 4th directive and 5th directive, and notably the reinforcement of the risk-based approach, the distinction between identifying and verifying the identity of clients; new provisions concerning the identity verification measures, including the requirements for obliged entities to consult the register of beneficial owners of client companies listed in the Trade and Companies Register, except where the risk is low; the introduction of the concept of beneficial owner of last resort or the reinforcement of the additional diligence measures when the transaction involves a high-risk country. Specific explanations are provided on the regimes for third-party introducers and outsourcing of AML-CFT obligations.