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CDP is among the persons engaged in financial activities subject to the Legislative Decree n. 231 of 2007, which, in order to promote at a national level, in compliance with European Directive 2015/849, the prevention of the use of the financial system for the purpose of laundering the proceeds of crime and financing of terrorism
In order to fulfill the obligations of Customer Due Diligence, CDP gathers all the necessary information on the beneficiaries of their products or services by filling out the appropriate forms, distinguished on the basis that the other party is or is not a Natural Person.
The information must be confirmed by a suitable attestation provided by a credit or financial institution covered by the Directive EU 2015/849 with whom the counterpart of CDP maintains an ongoing relationship in place (for example, a current account) in connection with which it has already been identified in person.
In cases where, for clear and sound reasons, it is not possible to acquire the suitable attestation by financial intermediaries, CDP itself ensure the verification of the information reported by the counterparty, acquired by completing the following special forms:
When the due diligence has already been carried out with reference to the customer and the beneficial owner in relation to the existing relationship with CDP and to be valid in accordance with the provisions contained in corporate procedures, CDP shall identify and verify the identity of any new executor who is acting for the first time in the name and on behalf of the client, acquiring the necessary information using the following appropriate form: Mod.005 Executor Self Verification.
The fulfillment of the obligations of due diligence in respect of credit and financial institutions established in non-EU countries not equivalent from the point of view of money laundering legislation consists in the acquisition and verification of information in order to know the ownership structure of the counterparty, to understand the nature of the activities, identify the system of supervision and controls against money laundering which the counterparty is subject. To this purpose, the CDP has adopted a specific form:
In order to complain with Public Administration due diligence, CDP has adopted a specific form:
In order to quantify the aggregated exposure of its customers to the MSC, CDP has sadopted a specific form which, being an integral part of the process of customer due diligence, has the purpose of identifying the counterparties involved, directly or indirectly with the MSC:
Financial intermediaries subject to anti-money laundering legislation are required to keep records and retain information that they have acquired to fulfill the obligations of customer due diligence, so that they can be used for any investigating possible money laundering or terrorist financing or analysis carried out the Financial Intelligence Unit (FIU) or any other competent authority.
In particular, CDP establish a single IT Archive for the recording and the storing of information on relationships with customers and the transactions that they made.
Financial intermediaries subject to anti-money laundering legislation are required "active" collaboration in order to implement effective prevention and repression of money laundering and terrorist financing, which results in the obligation to submit to the Financial Intelligence Unit (FIU) a suspicious transaction report when they know, suspect or have reasonable grounds to suspect that is being or has been committed or attempted transactions related to the events in question.
In order to fulfill the obligations of reporting of suspicious transactions, CDP requires all its organizational entities (business, support and control units), that for whatever reason could acquire elements which give rise to the suspicion, to initiate the procedure for reporting in accordance with the provisions of corporate regulation, tracing the processes of evaluation and decision-making also by filling in the appropriate form.