CDD in 10 steps
Step 2 - Identify your client
Reading time: 4 min
In short
Compliance with the AML in 10 steps; it seems simple, but what needs to be done? We discussed the first step in our previous blog, "Does the AML apply to you?". Whether you are subject to the AML depends on whether you qualify as an institution as defined by the AML. Please note that the AML is regularly supplemented with additional guidelines. The fact that you are currently not subject to the AML does not mean that this legislation will not apply to you in the future.
This second blog discusses the second step: identifying your client. This step must be performed before you provide services. Identification is defined in the AML as "statement of identity".
In order to identify your client, some information must be requested and also recorded in, for example, the client file, central records, or a combination thereof.
Identifying your client requires requesting various details and recording these in, for example, the client file, the central administration or a combination thereof. The recording of the identity and verification data of your client should be accessible so that a report can be made and a check can be carried out easily if necessary. The recording must be done in accordance with the GDPR.
Natural person
The following must be recorded for a client/natural person and if applicable, their representative:
- Last name
- First name(s)
- Date of birth
- Address, place of residence/business
- Transcript/copy of the document with a personal identification number with which the identification took place
Dutch legal entities
For legal persons incorporated under Dutch law, the following must be recorded:
The legal entity:
- Legal form
- Statutory name
- Trade name (if available)
- Address with house number and postal code
- Place of business
- Country of registered office
- Chamber of Commerce registration number and registered office of the Chamber of Commerce
- Methods used to verify identity
Representative of the legal entity
- First name(s)
- Last name
- Date of birth
Foreign legal entities
The following must be recorded for foreign legal entities:
The legal entity:
- The documents, data or information used to verify their identity
Representative of the legal entity
- First name(s)
- Last name
- Date of birth
In the third step of CDD, the client information must be verified. More about this can be read in our next blog: "CDD in 10 steps: Step 3 - Verify your client"