Updated 05/02/2025
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Initial Legal Act
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ANNEX II - Directive 2015/849 (AMLD 4)

ANNEX II

The following is a non-exhaustive list of factors and types of evidence of potentially lower risk referred to in Article 16:

(1)

Customer risk factors:

(a)

public companies listed on a stock exchange and subject to disclosure requirements (either by stock exchange rules or through law or enforceable means), which impose requirements to ensure adequate transparency of beneficial ownership;

(b)

public administrations or enterprises;

(c)

customers that are resident in geographical areas of lower risk as set out in point (3);

(2)

Product, service, transaction or delivery channel risk factors:

(a)

life insurance policies for which the premium is low;

(b)

insurance policies for pension schemes if there is no early surrender option and the policy cannot be used as collateral;

(c)

a pension, superannuation or similar scheme that provides retirement benefits to employees, where contributions are made by way of deduction from wages, and the scheme rules do not permit the assignment of a member's interest under the scheme;

(d)

financial products or services that provide appropriately defined and limited services to certain types of customers, so as to increase access for financial inclusion purposes;

(e)

products where the risks of money laundering and terrorist financing are managed by other factors such as purse limits or transparency of ownership (e.g. certain types of electronic money);

(3)

Geographical risk factors:

(a)

Member States;

(b)

third countries having effective AML/CFT systems;

(c)

third countries identified by credible sources as having a low level of corruption or other criminal activity;

(d)

third countries which, on the basis of credible sources such as mutual evaluations, detailed assessment reports or published follow-up reports, have requirements to combat money laundering and terrorist financing consistent with the revised FATF Recommendations and effectively implement those requirements.