In alignment with principles provided by key financial market associations, Clearstream explained today how it supports transfer agents in their AML (Anti Money Laundering) and KYC due diligence measures.
Enhanced due diligence on Clearstream
As the Luxembourg based ICSD, Clearstream said it performs enhanced due diligence on direct customers pursuant to Art. 19 of Directive (EU) 2015/849. Transfer agents should do an enhanced due diligence on Clearstream Banking S.A. rather than performing due diligence directly on Clearstream’s customers. Luxembourg is an EU and Financial Action Task Force (FATF) member state and not on the FATF list of countries that have been identified as having AML deficiencies.
Transparency reports for transfer agents
The transparency reports delivered to transfer agents reflect the positions/transactions performed by each Clearstream underlying customer.
Ultimate Beneficial Ownership identification
Clearstream also said that it provides reports to help transfer agents identify whether one or several Clearstream Banking S.A. underlying customers hold more than 25% of a fund. When a TA identifies such holdings, Clearstream will contact each specific customer to find out whether one or several UBOs hold more than 25% of the fund. When a transfer agent wants to identify the UBO for an account held by Clearstream as a nominee, they should consider the UBO of Clearstream Banking S.A.