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Comment on paragraph 2.9 of the draft revised guidelines: It is generally possible to independently determine/verify the jurisdiction in which the customer is based or resident (e.g. on the basis of the customer’s ID card) and the jurisdictions where it has its main places of business (e.g. on the basis of public databases). However, there are generally no sources available to verify the jurisdictions to which the customer has personal, business, financial or legal interests. We would therefore suggest to amend this paragraph so as to make clear that firms should consider the risks mentioned under a) to c) to the extent they can verify the information provided.
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