EU AML reform – CDD, in-depth

Susannah Cogman (+44 (0)20 7466 2580, susannah.cogman@hsf.com) is a partner and Ali Grodzki (+44 (0)20 7466 6329, ali.grodzki@hsf.com) an associate at Herbert Smith Freehills.

The EU AML reform package, published in July [2021] [1], includes proposals for a new Regulation [2] on AML/CFT, which features directly applicable, more detailed and granular requirements of EU-regulated entities when conducting customer due diligence (CDD). Susannah Cogman and Ali Grodzki of Herbert Smith Freehills examine key clarifications and amendments, in particular those relating to identifying the customer’s beneficial owner (BO) and determining the nature and extent of CDD measures.