Are advisers under Art. 2 para. 3bis and 3ter AMLA required to notify discrepancies under the Transparency Act (LETA)?
Antwort
No. The notification obligation under Art. 30 LETA applies only to financial intermediaries within the meaning of Art. 2 para. 2 and 3 AMLA. Advisers have the right to access the Transparency Register but are not subject to the discrepancy notification obligation.
Weitere relevante Fragen
Is the Communication Generator free to use?
Yes. The Communication Generator is free to use.
Does every shareholder or member qualify as a beneficial owner?
No. The fact that a company requests information from a shareholder or member does not automatically mean that this person is a beneficial owner. Indirect structures, acting in concert and other means of control may also be relevant.
Does the Communication Generator identify the beneficial owners?
No. The generator supports communication and information gathering. The actual assessment of who qualifies as a beneficial owner and who must be reported to the transparency register takes place afterwards. Konsento’s Transparency Register Reporting Assistant can be used for this assessment.