Fight Against Money Laundering -2

The scope of due diligence, previously limited to the financial sector now includes notaries, lawyers, accountants, auditors, tax advisers, estate agents, casinos, service companies and trusts, and insurance intermediaries . Monitoring the client is also extended to (s) recipient (s) number (s) [5] of the transaction: this additional requirement of identification, which seems difficult to implement, more complex work of banks.


The duty of care is now adjusted according to the risk that the client is. Each institution will define the level and nature of audit to be implemented towards the customer (identification and verification of identity on the basis of documentary evidence, gathering information on the purpose and nature of the relationship of business, followed by the business relationship ...) depending on the nature of its clientele, operation and services. The approach could also requires banks to be able to justify the adjustment of the audit.


To avoid duplication of identification procedures, the third directive sets up the principle of mutual recognition and acceptance of measurement results to identify clients: it allows the presentation of clients whose identification measures were carried out by banks and financial institutions located in the European Union. The ultimate responsibility then rests on the establishment to which the customer is introduced, that is to say the one who resorts to colleagues.


Banks have gradually established since the 1990s services fight against money laundering. They now emphasize the need for a group.

The first challenge for financial institutions is to continuously develop the culture of anti-money laundering with the group, and the training of employees by raising awareness (transmission of procedures and corresponding obligations, formation of the entire profession with warning indicators, lead to detect suspected cases ...). FBF offers on this since 2003, with the participation of Tracfin, a training evolution available to the entire profession, and consists of an awareness module and several modules specialized on specific issues.