NVB responds to European proposals for an effective UBO register

In response to the proposed revision of the European Anti-Money Laundering Directive (AMLD VI) and the AML Regulation, the Dutch Banking Association (NVB) makes a number of proposals to maintain and strengthen the effectiveness of the UBO investigations and the registers in the fight against money laundering.

For example, the NVB proposes to leave the threshold for registration in the Ultimate Beneficial Owner register at an interest of 25% or more. By doing this, banks and other bodies are prevented from spending a lot of time establishing the identity of relatively small shareholders and ensuring that efforts are focused on larger shareholders who also pose the greatest money laundry risk. Furthermore, banks must keep some room to implement the measures they take to determine the identity of a UBO in a risk-oriented manner. And finally, the role of public authorities in the Member States in maintaining the quality, accessibility and reliability of the various UBO registers must be strengthened.

Position Paper - Ultimate Beneficial Ownership