Markets where there is no obligation on Clearstream Banking as custodian to disclose account holders to issuers and/or regulators
In markets referred to under Category 3, Clearstream Banking is not aware of an obligation for Clearstream Banking to disclose, as a (sub-)custodian, account holders or customer holdings to issuers and/or local regulators.
Clearstream Banking may, however, receive disclosure requests that, if they appear to be legitimate, it might forward to its customers without further investigating their validity. Customers are advised to seek legal guidance on the existence and scope of any potential disclosure requirements with direct regard to such customers and their holdings. Clearstream Banking is not responsible for advising customers on the validity and scope of disclosure requests forwarded to customers.
Specifically, customers are informed and acknowledge that voluntary disclosure of customer holdings and of the corresponding beneficial ownership may be a prerequisite for obtaining relief from withholding tax on income payments.