Client identification 

In the context of the fight against money laundering and terrorist financing, the Prevention of Money Laundering and Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme) applies to services provided by, among others, tax advisers. This Act implements EC Directive 2005/60/EC on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing. This Act requires TCO to identify the client before entering into a business relationship.

Domestic legal entities can be identified by means of an extract from the trade register or a deed from a notary. The identity of a foreign legal entity can be established, for example, on the basis of an extract from the trade register of the country of origin or on the basis of other documents customary in international traffic that are recognised by law as a valid means of identification in the country of origin. It is also required that we request and keep the names and date of birth of the person acting on behalf of the legal entity.

With regard to domestic and foreign legal entities, except in exceptional cases, the ultimate beneficial owner must also be identified. The ultimate beneficial owner is the natural person who, directly or indirectly, owns more than 25% of, or otherwise has control over, the client.

For example, natural persons can be identified on the basis of a passport. An additional investigation must be carried out in the case of clients from abroad who are regarded as politically exposed persons.

If you have any questions regarding the implementation of the Money Laundering and Terrorist Financing (Prevention) Act by TCO, you can address them, preferably by e-mail, secretariaat@totalcompliance.nl