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 Fund Centre (CFCL)¹ informs fund transfer agents that requests for Ultimate Beneficial Owner (UBO) disclosure will be handled by CFCL 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.

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

CFCL 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 CFCL’s eligibility criteria allows only customers considered to be equivalently regulated financial institutions for the purposes of opening securities accounts that CFCL classifies as a form of correspondent banking relation. Therefore, "natural persons" cannot open accounts with CFCL.

Further information

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

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1. Clearstream Fund Centre refers to Clearstream Fund Centre S.A. registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-261691.