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Client’s ownership and management structure and beneficial owner
Where the client is a legal entity, trust or endowment fund, the bank is obliged to identify the management structure and all companies in the ownership structure above the client and verify the same against a reliable source, i.e. most often against an extract from a public register maintained by the Czech Republic or another state, an annual report, list of shareholders, etc.
The management structure includes the client's statutory body and the statutory bodies of all companies that directly own the client.
As part of client due diligence, the bank is also obliged to identify all beneficial owners and verify their identity against reliable sources.
If the client is required to be registered in the Register of Beneficial Owners, the bank always verifies the beneficial owner against at least this register and one other source, while also taking into account acting in concert. ( Act on the Registration of Beneficial Owners).
Thus, the client may be asked to submit documents establishing the management and ownership structure or the beneficial owner, if the relevant register/information is not publicly available.
In the case of a branch, the bank identifies the ownership structure and beneficial owner of the founding legal entity.
The bank checks whether the client, beneficial owner or persons in an ownership or management function are politically exposed persons or subject to international sanctions.
For more information, also see Founding a legal entity (CZ).
Publicly available registers:
Raiffeisenbank a.s. performs client due diligence to eliminate the risks of money laundering and terrorist financing to the greatest possible extent. Client due diligence is often known as "Know Your Customer". At the bank's request, every client is obliged to provide the information necessary for the due diligence and to submit the relevant documents. If the client fails to provide such cooperation or if the client due diligence cannot be carried out for any other reason, the bank must proceed in accordance with applicable laws.
The bank ascertains and evaluates information on the purpose and nature of the transaction or business relationship, the nature of business activities, information on the identification and verification of the client's beneficial ownership and identification of the client's management and ownership structure, and information on the origin of assets of a politically exposed person or on the application of international sanctions to the client. In accordance with Sec. 9a of Act No. 253/2008 Coll., the bank carries out enhanced identification and due diligence of clients with a high-risk third country as their country of origin, all at any time during the establishment or existence of the business relationship. The list of high-risk countries is determined on the basis of Commission Regulation (EU) 2016/1675 and the FATF list of high-risk countries. From the bank's perspective, AML (Anti Money Laundering) rules must be adhered to. These are anti-money laundering measures that are also intended to combat the financing of terrorism (CFT).
The bank treats all client data and submitted information in accordance with the principles of banking secrecy.