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Law on the Prevention of Money Laundering and Terrorist and Proliferation Financing.

Outsourced bookkeepers were given a new obligation -  to identify their clients. If this is not done, the penalties are inadequately severe. 

How is the client identified?

Before starting a business relationship, the Client identification form must be filled in. Even if there is only one transaction (eg preparation of an annual report), information about the potential client must be collected as well.

How does the bookkeeper identifies a legal entity?

- asks to present documents confirming the establishment, status, purpose and name of the legal person;

- requests information on the client's legal address and the actual place of performance of business activity;

- the bookkeeper must also obtain information from a publicly available, reliable and independent source;

- the true beneficiary must be identified.

A natural person - an operator of business activity is similarly identified.

Abstention from performing a transaction if:

- the transaction amount or the total amount of several related transactions is 10,000 euros or more;

- a transfer of funds is made, including a credit transfer, direct debit transfer, non-cash transfer made with a payment card, electronic money instrument or other information technology and exceeding 1000 euros;

- a foreign currency cash purchase or sale transaction exceeding 1000 euros is performed;

- the transaction complies with at least one of the characteristics included in the list of characteristics of an unusual transaction (Regulations on Detection of Unusual and Suspicious Transactions), or money laundering is suspected (Regulations on Procedures for Assessing Customer-Related Money Laundering and Terrorism, and Proliferation financing risk");

- doubts arise as to the veracity of the information obtained from the initial identification.

If there is a suspicion of illegal transactions of a potential client, then a special form "Report on an unusual or suspicious transaction" needs to be filled in and submitted to the State Revenue Service.