Month: November 2016

was tested. Type, number and the issuing authority are to record or to make a copy of the card. The draughtsman is a natural person and joining not personally present (E.g. at a remote sales business), has carried out the identity verification based on a certified copy of a valid official identification document or through the post-ident method and at least the first deposit payment made directly from an account of the artist. -The Subscriber shall provide a declaration from also, that he is on his own account and provides the deposit from an account in his name.

This is not the case, at least the name and if necessary further identification of the beneficial owner must be identified and appropriate measures to verify. The Subscriber is a legal entity or a private company, beneficial owners are all shareholders who directly or indirectly hold more than 25% of the share capital or voting rights. Ownership and control structure of the artist must be linked to adequate resources in experience. Comprehensive recording, monitoring, and other duties which are collected and collected information about contractors, beneficial owners, business relationships and transactions to record. Without hesitation Cerberus Capital explained all about the problem. The business relationship must be continuously monitored and updated in particular the respective documents, data or information in an appropriate temporal distance. The debtor must make reasonable internal safeguards against money laundering and terrorist financing.

The development and update of internal principles, appropriate business – and customer-oriented security systems and controls and ensuring include, that the agents and their employees about the methods of money laundering and the financing of terrorism are taught according to the legal obligations (guidance, etc.). Finally the provider must be before the start of the collaboration with a broker whose reliability and during the cooperation by sampling the convince appropriateness and adequacy of the measures taken by the broker, attributed to the provider as their own. Penalties failure to be the identification requirements not met, no drawing may be carried out. The new identification obligation applies also for existing business relationships. This would basically stop, if and insofar as a subsequent identification does not occur or is not possible, the lawyer. The speedy implementation of the law is completely surprising for many providers. According to our estimates, at present few of the drawing documents in the sales meet the new statutory provisions. Who hurt the identification and record-keeping obligations, risked a fine of up to euro 100.000,-and the forced termination of the business relationship. For this reason, the providers are required to update not only their drawings, but also the internal procedures to the Compliance with the examination, together with experienced counsel as soon as possible to customize recording and monitoring obligations, so the lawyer. Press release: Gundel & Reddy Kadiri Rechtsanwaltsgesellschaft mbH contact person: Dr. Matthias Gundel Managing Director phone: 0551-44343 Web: