4.25

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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 beneficial owner of a public administration or a state-owned enterprises (4.23-4.25)
4.25

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Version date: 1 March 2021 - onwards

Firms should also have due regard to the possibility that the senior managing official of the customer may be a PEP. Should this be the case, firms must apply EDD measures to that senior managing official in line with Article 18 of Directive (EU) 2015/849, and assess whether the extent to which the PEP can influence the customer gives rise to increased ML/TF risk and whether it may be necessary to apply EDD measures to the customer.

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