New feature: search engine screening!

Reading time: 2 min.

From now on it is possible to perform search engine screening in addition to your screening of natural persons or companies through various (sanction-)lists. This is perhaps the way in which you are currently also performing your customer due diligence screening. Then you probably also have experienced what a time-consuming job this is, not to mention the difficulty of assigning a risk assessment to the results found...

We have made this a lot easier for you! Simply enter the search term at CDD On Demand, which you would also have entered in the search engine and you will immediately see how many results the search term has, with a risk indication! Let's get in to the details;

What does a search engine screening entail?

With this screening you have the option to screen natural persons and companies through all public information provided by the search engine Bing. In CDD On Demand you will immediately receive a risk indication based on all the information found. This will save you a lot of time and takes away a lot of hassle!

How does the screening work?

In addition to CDD On Demand proposing a number of good search terms, you also have the option of adding an extra search query, eg “Jantje + Money Laundering”. You get to see how many results have been found for this search and based on the results you will also receive a risk indication. U krijgt vervolgens te zien hoeveel resultaten er zijn gevonden voor deze zoekopdracht en op basis van die resultaten ontvangt u ook een risico indicatie.

Green = No results, this search probably does not indicate an increased risk.

Orange = Less than 10 results, this search may indicate an increased risk.

Red = More than 10 results, deze zoekopdracht geeft mogelijk een indicatie voor een verhoogd risico.

Why has the search engine screening been added?

This search engine screening serves as an additional safety, to identify possible risk indicators that may not have been identified when consulting previous data sources. An extra assurance! Better be safe than sorry! Better be safe than sorry!

Want to try it yourself?
Would you like to have a supporting tool for your customer due diligence screenings? CDD On Demand is the solution for you. With CDD On Demand you are able to screen through various (sanction-)lists, monitor your clients 24/7, perform UBO checks* and perform a search engine screening from now on!

Request free credits now and discover the features with trial account.

*Performing a UBO check is not possible with a trail account. Contact us for more information about our UBO check.

The Annual budget: the wealthy have to absorb the blow among others

Reading time: 3 min.

Last Tuesday was a very special Prinsjesdag. Not only did the COVID-19 virus dramatically change the ceremony, it also had a significant effect on changing the Annual budget (Miljoenennota) itself. Multinationals, the wealthy, the self-employed, and large companies without investments are going to have a difficult time in the coming year. On the other hand start-up companies, people with savings, and people on fixed salaries receive tax advantages. Pension rebates are expected to go primarily towards the public and healthcare sectors.

The government expects a budget deficit of 43 billion in 2021, and of 53 billion in 2020. Corona-related aid packages for businesses amounts to 46 billion in this fiscal year. Next year the estimated budget deficit is estimated to be 61% of GDP due to falling tax revenues.

Box 3 is addressed

The capital gains tax will be addressed next year. The tax-free capital, the amount of capital for which no tax must be paid, is increased from 30,846 euros to 50,000 euros. On the other hand, the wealthy with more than 50,000 euros will pay more capital gains task. On the calculated returns you no longer pay 30 percent taxes, but 31 percent.

Middle-class and start-ups get more benefits

By reducing the first income tax bracket and increasing the employment discount, the middle class is expected to grow about two percent on their net salary during the next year. The government also wants to help start-ups in the crowded housing market. An example is scrapping transfer tax for persons between the 18-35 years old who purchase their first. Investors who aim to buy a second (or third, fourth etc.) property to rent out must pay 8% tax on the transaction.

Action equals reaction?

The changes highlighted above are summarized from the Annual budget, these changes may affect starters, the middle class, and the wealthy, and they may cause changes in behavior as well.

The withdrawal of highly taxed investors from the housing market may create more room for first-time buyers, and as a result realtors and notaries will see an increased number of clients. The former will assist in the purchase of property, while the latter draws up purchase contracts, mortgage deeds, and the occasional co-habitation contract. The influx of new clients also means that realtors and notaries need to spend more time on client investigations, which can be quite time-consuming.

Just as these changes from the Annual budget may create an abundance of work for notaries and realtors, the same may happen for asset managers. Investors which might be deterred from investing in housing may instead opt to invest their capital through asset managers. Accepting new clients represents a high workload for asset managers, as their inventarisation procedures are very extensive. In addition to the Customer Due Diligence components of this procedure, which is also mandatory for realtors and notaries, asset managers also need to go through so-called "Know Your Customer" procedures. This step requires the creation of a comprehensive inventory which maps a client’s family situation, their financial position, and their knowledge of financial markets and previous experience

You can read more about the difference between CDD and KYC in our blog.

Conclusion

The new policy presented in the most recent Budget Memorandum could provide a boost of new customers at various organizations subject to the Wwft, such as brokers, civil-law notaries and asset managers. However, a thorough Wwft client due diligence takes a lot of time because it is difficult to meet all the requirements imposed by the Wwft. It is also difficult to keep an eye on what changes have been made to the continuously changing Wwft.

SCOPE FinTech Solutions has therefore set up CDD On Demand to support small to medium-sized companies in their Wwft obligations. You can purchase credits yourself via the webshop with which you can conduct a Wwft client investigation within three seconds. Based on this, it is checked within a few seconds whether your client poses an increased risk at one of the checked points, which means that you may need to perform an enhanced customer due diligence.

The CDD On Demand solution also offers the possibility to monitor your clients daily for new or additional risk factors, in which case you will receive a notification immediately. Finally, CDD On Demand offers the possibility to try to find out the UBO behind an authority or organization. At the end of the check you will receive a certified report for your own records.

Better safe than sorry!

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AMLD for real estate agents

Since the introduction of the Fourth Anti-Money Laundering Directive estate agents are required to have a Customer Due Diligence policy. This means, among other things, that agents are obliged to conduct a client survey to determine whom they do business with, and what risks are associated with that.

Anti Money Laundering Directive (AMLD)

The AMLD has been drawn up to prevent money laundering and terrorist financing. The AMLD has been in force in the Netherlands since August 1, 2008, and was last amended on January 10, 2020 to the fifth European anti-money laundering directive (AMLD5). Under the AMLD, transactions concerning real estate are also included, which entails additional obligations for brokers, appraisers and intermediaries in transactions concerning real estate.

What does the AMLD mean for real estate agents?

The most important elements of the AMLD are customer due diligence, the notification obligation and the retention obligation. In summary, this means that a broker must investigate the parties that are being brokered between to determine who they are. In addition, the broker is obliged to investigate whether there is a risk of money laundering or the financing of terrorist agencies.

This client investigation is also referred to as the client investigation or the Customer Due Diligence (CDD).

In addition, every broker is required by the AMLD to have a written standard policy for this. This must comply with the guidelines given by the Central Government regarding AMLD for estate agents.

Client research and Customer Due Diligence (CDD)

The first step in standard customer due diligence is to establish and verify the identity of the client and counterparty in a transaction. This means that the auditor must verify whether the documents provided are authentic, whether they are consistent with the parties involved, and whether no external interested parties are involved in the transaction.

Bij transacties met een bedrijf of instantie moet de makelaar identificeren wie de Ultimate Beneficial Owner (UBO) is en hier het cliëntenonderzoek op toepassen. De verstrekte identificatiegegevens en documenten dienen vast te worden gelegd in een klantenbestand conform met de betrokken bewaarplicht van het Wwft.

In addition to the investigation into the identity of the parties involved, the AMLD also requires the broker to conduct an investigation into the risk profile of these parties. The risk profile is an indication of the risk of money laundering or terrorist financing that clients entail. Examples of situations that entail an unacceptable risk under the AMLD are clients who use false identities, possess inexplicable assets, or act on behalf of non-transparent foreign bodies. To determine a risk profile, the Central Government recommends using the risk matrix AMLD for brokers of the tax authorities.

Duty to report

If the broker's customer due diligence reveals an increased or unacceptable risk of money laundering, the broker is obliged to report this to the FIU (Financial Intelligence Unit) of the national government. The duty to report also applies if the customer due diligence does not yield the desired results, or if a transaction can be seen as unusual. The FIU then decides whether the unusual situation is actually suspicious, and takes further action or asks the reporting person for more information.

When submitting a report, the broker is also obliged to adhere to a stricter retention obligation.

Data retention obligation

The retention obligation obliges a real estate agent to keep all data regarding customer due diligence for at least five years, and to make it accessible for any further investigation. Once a report has been made to the FIU, this obligation also applies, with a stricter requirement for the storage of data. In this case, all data required to reconstruct the transaction, a copy of the notification and a confirmation of receipt from the FIU must also be kept.

Enhanced customer due diligence

As a result of the identified parties, there may be grounds for stricter customer due diligence. Examples of reasons for tightening up the investigation are: the relationship of parties from risk countries or politically exposed persons, transactions by means of cryptocurrencies, or if one of the parties is negatively known to a financial regulator.

The guidelines for initiating an in-depth investigation can be found in section 5.3 of the AMLD guidelines for brokers.

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