Investment funds: Requests for Ultimate Beneficial Owner disclosure

Note: Further to Announcement A19113, this announcement has been republished as the information is now applicable to all entities (CBL, CEU OneClearstream, CEU and CFCL).

Clearstream Europe¹ informs fund transfer agents that requests for Ultimate Beneficial Owner (UBO) disclosure will be handled by Clearstream Europe if the following conditions are met:

• An official request is received from the fund transfer agent with a business justification for the reason for disclosure (to be sent by email or Swift).
• The request should contain the ISIN, the date for which a disclosure is required and the deadline to provide information. If the disclosure must be done on Umbrellas, transfer agents must provide the “Umbrella-to-ISIN” mapping.

Depending on the request, an hourly fee for special operational services could be applied.

Clearstream Europe only acts as an intermediary between the transfer agent appointed by the fund and Clearstream Europe clients and therefore cannot guarantee that these clients will disclose any information and the content of any information disclosed.

Clearstream Europe cannot guarantee a time to respond as it will depend on the responsiveness of the underlying client.

For UBO requests related to the Luxembourg register of ultimate beneficial owners implementing provisions of the 4^th AML Directive into Luxembourg Law, transfer agents or fund companies should make use of the existing client holdings reporting made available to transfer agents. If and when direct clients holding more than 25% of a specific fund issuance are identified, a UBO request can be raised by the transfer agent (see above conditions). Requests must detail the 25% threshold in shares/market value to allow direct customers to complete their review.

Transfer agents and fund companies are reminded that Clearstream Europe's eligibility criteria allows only clients considered to be equivalently regulated financial institutions for the purposes of opening securities accounts that Clearstream Europe classifies as a form of correspondent banking relation. Therefore, "natural persons" cannot open accounts with Clearstream Europe.

Further information

For further information please contact Clearstream Client Services or your Relationship Officer.

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1. This Announcement is published by Clearstream Europe AG (CEU), registered office at Mergenthalerallee 61, 65760 Eschborn, Germany, registered with the Commercial Register of the District Court in Frankfurt am Main, Germany, under number HRB 7500.