New AML duties with need for clarification
The most recent revision of the Anti-Money Laundering Act obliges financial intermediaries to verify the identity of the beneficial owner and to periodically review and update the client file from 1 July 2022. As more specific rules by way of ordinance or self-regulation are not envisaged, it is incumbent on the institutions to determine the content and practical details of the partially unclear statutory amendments. Our Client News show the room for interpretation and how the new duties could be reasonably implemented. Being largely technical in nature, they are available in German only.