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CDD in 10 steps

Step 3 - Verify your client

Reading time: 4 min

In short

In the previous blogs, we covered the first two steps of the Customer Due Diligence (CDD) obligation under the AML. The first step was to check whether you need to comply with the AML at all, i.e. whether you are subject to the AML. The second step involved identifying your client. Once those steps are completed, it is time for step 3: verify your client.

Verifying your client means that you must verify the specified identity from step 2 with the actual identity. This step must also be completed before the service is provided. The AML does not prescribe exactly how the identity of a client must be verified, but a number of documents have been listed that at least meet the legal standard. To verify your client, a distinction must first be made between the different types of clients.

 

The AML does not prescribe exactly how the identity of a client must be verified

 

Verifying your client means that you must verify the specified identity from step 2 with the actual identity. This step must also be completed before the service is provided. The AML does not prescribe exactly how the identity of a client must be verified, but a number of documents have been listed that at least meet the legal standard. To verify your client, a distinction must first be made between the different types of clients.

 

Natural persons

The identity of natural persons can be verified by the following documents:

  • A valid passport;
  • A valid Dutch driving license or EU/EEA driving license with a passport photo and name of the holder;
  • A valid identity card issued by a Dutch municipality or by the competent authority in another EU/EEA member state and provided with a passport photo and name of the holder; 
  • In some cases, the identity can also be verified based on a valid residence or travel document.

 

 

Dutch legal entities and foreign legal entities with an establishment in the Netherlands

For legal entities established in the Netherlands, their identity can be verified using:

  • An (online) extract from the Trade Register of the Chamber of Commerce or a deed; 
  • A statement drawn up or issued by a lawyer, civil-law notary or junior civil-law notary established in the Netherlands or in another EU/EEA member state or a comparable independent practitioner of a legal profession.

A certified extract from the Chamber of Commerce is no longer necessary. An online extract is now also sufficient, provided the application has been made by the institution.

Foreign legal entities with no establishment in the Netherlands

For foreign legal persons without an establishment in the Netherlands, the identity is verified using reliable documents, data or information commonly used in international trade or documents, data or information that are recognised by law as a valid means of identification in the state of origin.

Once you have verified the identity of your client, it is time for the next step. This step only applies if your client is a legal entity as the Ultimate Beneficial Owner (UBO) must be determined. More about this in the next blog!

 

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