Supporting Transfer Agents in performing KYC and enhanced due diligence on Clearstream

Clearstream helps transfer agents in their Anti Money Laundering (AML) and KYC due diligence measures in alignment with principles provided by key financial market associations.

Luxembourg law and regulations

Clearstream is subject to the Luxembourg laws and regulations which define the framework under which Clearstream implemented its Compliance, AML and Counter Terrorism Financing (CTF) programme. Luxembourg is an EU and Financial Action Task Force (FATF) member state and not on the FATF list of countries that have been identified as having AML deficiencies.

Enhanced due diligence on Clearstream

Clearstream Banking S.A. performs enhanced due diligence on direct customers pursuant to Art. 19 of Directive (EU) 2015/849. Transfer Agents should do an enhanced due diligence on Clearstream Banking S.A. rather than performing due diligence directly on Clearstream’s customers. No documentation/account opening form should be requested to those customers except in case of risk-based scenarios. This includes the identification/disclosure of Ultimate Beneficial Owners (UBOs).

Transparency reports for transfer agents

The transparency reports delivered to transfer agents reflect the positions/transactions performed by each Clearstream underlying customer.

Ultimate Beneficial Ownership identification

Clearstream provides reports to help Transfer Agents identify whether one or several Clearstream Banking S.A. underlying customers hold more than 25% of a fund. When a transfer agents identifies such holdings, Clearstream will contact each specific customer to find out whether one or several UBOs hold more than 25% of the Fund. When a transfer agent wants to identify the UBO for an account held by Clearstream as a nominee, they should consider the UBO of Clearstream Banking S.A.