In our response we acknowledge the importance of the FATF document as it contains numerous case studies whereby specific structures are abused to conceal the beneficial owners.
We further point out that there is a widening gap between the obligations applicable to financial intermediaries and those applicable to other professions.
Hence we want to avoid new requirements and recommendations for financial intermediaries.
And we also mention that digital solutions supported by government agencies or official authorities are probably more efficient.

IBFED Response to FATF_5 April 2018_Beneficial Ownership

 

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