Client Identification

The European Parliament adopted a Directive by the end of 2001 (No. 2001/97/EC) which extends the identification obligation and the reporting obligation in respect of unusual transactions in an attempt to fight against money laundering .

As a result of this extension the Disclosure of Unusual Transactions Act (in Dutch: abbreviated "MOT") of 1993 and the Identification Provision of Services Act (in Dutch abbreviated "WID") will also apply to the services provided by lawyers, attorneys, notaries, tax advisors and accountants starting 1 June 2003. The provisions of the relevant Acts impose by law that these advisors are under a statutory duty to conduct proper identification of a client before accepting instructions and providing advisory services. Domestic legal entities or foreign corporations operating through a corporate vehicle in the Netherlands and registered as such with the Chamber of Commerce will be identified by means of a certified extract from the Chamber of Commerce and a copy of a valid ID (passport or driving license, or other official documents) proving the identify of the representative of the legal entity. Legal entities that are incorporated and registered abroad and do not hold a branch office in the Netherlands will be required to submit a certified extract concerning their registration from the country where they have their registered seat. To the above rules there are exemptions e.g. for referrals between professionals where within the European Community a single identification may suffice.