Financial Crime Compliance
Protecting our businesses from money laundering and terrorism financing risks
As a financial institution, DLL plays an important role in detecting and preventing money laundering, terrorist financing, sanction violations and fraud. As part of the global Rabobank Group, we recognise our responsibility in ensuring our financial system remains healthy and free from financial economic crime. Keeping our customers, partners and DLL safe and protected will always be a top priority for us.
Why?
DLL, as with other financial institutions, is subject to laws (including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006) which place obligations on us to apply identification and verification procedures to our partners and customers prior to onboarding.
How do we keep our businesses safe?
DLL performs Customer Due Diligence (CDD) on all customers and partners before onboarding. DLL identifies and verifies the Ultimate Beneficiary Owner(s) (UBO) of your/your customers organisation so we understand who we are in business with, the reasons behind the transactions and the risks involved.
What is an Ultimate Beneficiary Owner and how do I identify them?
Check out our explanation video on the right. In short, a UBO is a natural person(s) in your or your customers organisation who:
- Directly or indirectly own(s) 25% or more of the shares in the share capital of a legal entity;
- Hold(s) 25% or more in voting rights in the meeting of shareholders of a legal entity;
- Directly or indirectly own(s) 25% or more interest or profit share in a legal entity; or
- A natural person(s) who otherwise exercises effective control (typically a senior managing official)
What information do I or my customers have to provide to DLL?
When identifying your UBOs we ask for the following UBO information: the full name, date of birth and residential address for each UBO.
When the UBO information is collected, DLL needs to verify that this information provided by you or your customer is true. The supporting documents DLL needs for verification differ per situation. This depends on your or your customers legal entity type and the type of financial solution you or your customer are applying for.
This means that the UBO identification and verification process might not be exactly the same for every application. We understand that this can be confusing and we wish it was a one size fits all. Unfortunately this is not the case, we try our best to make it as easy as possible for you and your customer. Generally, for Operating Lease and Rentals we need less information than when applying for a Finance Lease, Loan / Chattel Mortgage or Hire Purchase. You can find an indication of what we might ask for below.
Operating Lease and Rental: in case DLL cannot find the information via open sources, you or your customer fills out a UBO self-declaration form stating UBO information (full name, date of birth and residential address) for each UBO.
For Chattel Mortgage/IPA: more information is needed for verification than a self-declaration form. Depending on the entity type, this can include: an AML Certificate, a partnership agreement, a copy of government issued identification documents such as drivers licenses and passports, a trust deed.
FAQ
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