Accountor Kyiv Change of Status
On April 28, 2020, the Law of Ukraine “On Prevention and Counteraction to Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and Financing of Proliferation of Weapons of Mass Destruction” (hereinafter - the Law) entered into force. Due to this, new processes and approaches to financial monitoring activities have been introduced.
As an outsourcing provider of accounting and legal services, Accountor Kyiv LLC must register with the State Financial Monitoring Service of Ukraine (hereinafter - SCFM) as a subject of primary financial monitoring.
Under this Law, Accountor Kyiv LLC, as a subject of primary financial monitoring, is obliged to:
- analyze and take into account the purposes and legal bases of the Clients’ financial transactions (source of income / origin of funds (country / company), compliance of financial transaction with the Client's economic activities, unusually high amounts of transactions (compared to current activities), complex schemes of financial transactions, etc.);
- report to State Financial Monitoring Service on threshold transactions and suspicious financial transactions, as well as on discrepancies between the data on the ultimate beneficial owners of the Client (hereinafter - UBO) contained in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Associations (hereinafter - USR), and the data obtained as a result of due diligence investigation of the Client.
Transactions from UAH 400,000 are subject to mandatory primary financial monitoring.
A proper due diligence investigation of Clients includes:
- Detecting the Client’s UBO;
- Establishing the purpose and nature of future business relationships or of financial transactions;
- Monitoring the Client's business relations and financial transactions carried out during such relations on a permanent basis. Checking the compliance of such financial transactions with the information Accountor Kyiv LLC has about the Clients, their activities and possible risks;
- Ensuring the relevance of the existing documents and the documents received, of data and information about the Client.
Taking into account these requirements, we would like to inform you that Accountor Kyiv LLC may send you a request to provide relevant information for the investigation.
Accountor Kyiv LLC applies a risk-oriented approach to business activities, taking into account the relevant risk criteria, in particular, those related to Clients, geographical location of the Clients’ official seat or of the institutions through which the Clients transfer (receive) the assets, and to the ways of providing (receiving) services.
Please note that in case of data discrepancies or lack of data on the UBO in the USR, also in cases where the founders and participants are natural persons; or if the data on the UBO can be found in the information about participants and founders only, Accountor Kyiv LLC recommends that appropriate changes be made to the USR by providing information to the state registrar regarding your UBOs during the current month.
Taking into account that the status of Accountor Kyiv LLC has changed, and that the company must register as a subject of primary financial monitoring, we do hereby inform you of our change of status and of the related procedures in processing personal data of our Clients.
If you have any questions, please contact Katerina Lysechko, Head of Legal Department at Accountor Kyiv LLC: Katerina.Lysechko@accountorgroup.com.ua.
Take care of yourself and your loved ones!