Source: European Parliament
Article 13 of the EU Money Laundering Directive (2015/849/EU) lays down obligatory due diligence measures such as identifying the customer and verifying the customer’s identity. A further requirement is ‘conducting ongoing monitoring of the business relationship including scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the obliged entity’s knowledge of the customer, the business and risk profile, including where necessary the source of funds and ensuring that the documents, data or information held are kept up-to-date.’
Under Article 11 of the Directive, these due diligence measures must be applied when establishing the business relationship and in case of doubt as to the accuracy or suitability of previously-obtained customer identification data.
In the Commission’s view, is there an obligation under the Directive to repeat the verification of the identity of all customers at regular intervals, even if there are no doubts as to the accuracy and currentness of the customer identification data?