Whilst there is no legal requirement to put in place formal procedures for evidencing the identity of EP NL business partners, in forming new business relationship or considering undertaking a significant one-off transaction, it is expected and prudent for management of EP NL Group Companies to satisfy themselves as to the identity of the parties with whom they are transacting.
KYC Directive outlines the process that seeks to verify and validate the business partner’s identity and suitability in order to support EP NL’s actionable decisions to mitigate financial, regulatory and reputational risk and ensure regulatory compliance. It also sets basic principles for division of powers and responsibilities concerning the performance of the KYC procedure according to the KYC Directive among EP NL Group Company’s departments and bodies including the four eyes principle.
Before entering into or continuing a business relationship, EP NL Group Company carefully checks its (prospective) business partners by collecting information and data from public and other reliable sources or completion of a KYC Questionnaire and provision of necessary documentation by the business partner. EP NL Group Company evaluates and verifies the information and data, checks whether the business partner is subject to sanctions and assesses whether entering into a business relationship with the business partner may constitute a risk of non-compliance in the areas of money laundering, terrorist financing or tax governance fraud. Should the KYC procedure reveal any concerns or irregularities as regards the business partner’s identity and suitability, EP NL Group Company can decide not to enter into the business relationship or undertake the business transaction.
