The requirement to identify and verify customers and where applicable beneficial owners at any time where the Designated Person is obliged by virtue of any enactment or rule of law to contact a customer for the purposes of reviewing any relevant information relating to the beneficial owner connected with the customer;
an obligation on a Designated Person to ensure that beneficial owner of the customer has been entered into the applicable beneficial ownership register, if applicable, prior to conducting any transactions, including the receipt of any funds, on the behalf of the customer and/or Beneficial Owner;
where the Beneficial Owner is the senior managing official, Designated Persons are required to take the necessary measures to verify the identity of that individual and retain records of the actions taken to verify that individual’s identity including any difficulties encountered in the verification process; o in cases where the senior managing officials have been listed as the Beneficial Owners, Designated Persons are required to establish whether the customer in question has in fact exhausted all possible means to identify their Beneficial Owner(s);
Designated Persons are required to maintain their own lists of documentation which should remain current and appropriate and consider, evolving internal processes and any relevant external or environmental factors e.g., a pandemic; and
sources of information which can be used to identify and verify a customer’s identity to explicitly include information from relevant trust services as specified in the eIDAS Regulation.