The anti-money laundering regulations impose strict obligations on accounting firms to prevent and detect money laundering and terrorist financing. Some of these obligations involve carrying out customer due diligence measures (previously referred to as “customer control”).

The purpose of these due diligence measures is for reporting entities to know their customers — including who they are, the nature of the customer relationship, which services and products they use from the reporting entity, and the scope of the customer relationship. This is referred to as the “know-your-customer” principle, and is one of the most important tools for preventing and detecting whether the financial system is being misused for money laundering or terrorist financing.

By knowing the identity of the customer and the actual beneficial owners, as well as the purpose and intended nature of the customer relationship, the accounting firm can implement risk-based measures to detect and prevent money laundering and terrorist financing.

The accounting firm must be able to document to the supervisory authorities that it fulfils the statutory requirements for carrying out customer due diligence.

Once the customer relationship has been established, the accounting firm is obliged to follow up the customer relationship, including by monitoring that transactions are consistent with the information obtained as described above. We must keep this information up to date and must therefore periodically request updated information from customers. This must always be done if there is doubt as to whether previously obtained information is still correct.

The accounting firm may be obliged to decline customers or terminate customer relationships if the customer behaves in such a way that customer due diligence cannot be carried out in accordance with statutory requirements.