Updated 05/02/2025
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ANNEX III - Directive 2015/849 (AMLD 4)

ANNEX III

The following is a non-exhaustive list of factors and types of evidence of potentially higher risk referred to in Article 18(3):

(1)

Customer risk factors:

(a)

the business relationship is conducted in unusual circumstances;

(b)

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

(c)

legal persons or arrangements that are personal asset-holding vehicles;

(d)

companies that have nominee shareholders or shares in bearer form;

(e)

businesses that are cash-intensive;

(f)

the ownership structure of the company appears unusual or excessively complex given the nature of the company's business;

(2)

Product, service, transaction or delivery channel risk factors:

(a)

private banking;

(b)

products or transactions that might favour anonymity;

(c)

non-face-to-face business relationships or transactions, without certain safeguards, such as electronic signatures;

(d)

payment received from unknown or unassociated third parties;

(e)

new products and new business practices, including new delivery mechanism, and the use of new or developing technologies for both new and pre-existing products;

(3)

Geographical risk factors:

(a)

without prejudice to Article 9, countries identified by credible sources, such as mutual evaluations, detailed assessment reports or published follow-up reports, as not having effective AML/CFT systems;

(b)

countries identified by credible sources as having significant levels of corruption or other criminal activity;

(c)

countries subject to sanctions, embargos or similar measures issued by, for example, the Union or the United Nations;

(d)

countries providing funding or support for terrorist activities, or that have designated terrorist organisations operating within their country.