The Dutch Central Bank DNB published last January that they expect from supervised institutions like banks, payment providers and trust offices that they use information like the leaked papers to determine the risk profile and if necessary, carry out additional investigation and take adequate measures. These requirements are part of the Customer Due Diligence obligations for financial institutions and other institution based on the Dutch implementation of the Anti-Money Laundering Directive; the Wwft and Wtt 2018.
The International Consortium of Investigative Journalists, ICIJ, has collected information on more than 800,000 offshore entities that are part of the Pandora Papers (2021), Paradise Papers (2017), Bahamas Leaks (2016), Panama Papers (2016) and Offshore Leaks investigations (2013). ICIJ has organised and stored all this information in their database and publishes this information in the public interest. More information: https://offshoreleaks.icij.org/
By adding these sources of leaked papers in the IRIS Risk Analysis, our customers are able to develop a more comprehensive risk profile of their customers or business partners. The presence of a person or organisation in such a leaked paper does not directly link them to illegal activities, since there are several legitimate uses for offshore companies and trusts. It does however give a better insight into the organisational structure and helps determining who are the beneficial owners and key persons of international organisations, who can then be screened online for adverse scenarios and against international PEP and Sanction lists.
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