4.22

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Final Report - Guidelines EBA/2021/02 on customer due diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions ('The ML/TF Risk Factors Guidelines') under Directive (EU) 2015/849 (EBA/GL/2021/02) (updated 30 December 2024)
Guidelines
Title I: General Guidelines
Guideline 4: CDD measures to be applied by all firms (4.1-4.78)
Customer due diligence (4.5-4.39)
Beneficial owners (4.12-4.25)
Identifying the customer’s senior managing officials (4.19-4.22)
4.22

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Version date: 1 March 2021 - onwards

In those cases, firms should clearly document their reasons for identifying the senior manager, rather than the customer’s beneficial owner, and must keep records of their actions [Article 3(6)(a)(ii) of Directive (EU) 2015/849].

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