1. What is meant by the total number of clients?
It is the total number of clients that need to be identified. For example if we have as client company XYZ we need to identify and consider as clients the following natural and legal persons: Company XYZ, the shareholders of company XYZ, the directors of company XYZ, the signatories of company XYZ, the beneficial owners of company XYZ (if different than the shareholders).
2. I am employee, should I complete the questionnaire?
No you should only complete the declaration in appendix B.
3. I am co-operating with another lawyer, who should complete the questionnaire?
You should both complete the questionnaire.
4. We work only part time as lawyers, should we complete the questionnaire?
Yes, all members of CBA should complete the questionnaire.
5. I have a legal firm, should I consider myself as employee of my firm?
Yes you should complete the questionnaire for your firm and you should only complete the declaration in appendix B for yourself.
6. I have just opened my law firm, should I complete the questionnaire?
Yes, the questionnaire should be completed irrespective of the period your firm is in operation and the number of clients you may have.
7. In our firm there are 5 lawyers, should they complete five separate questionnaires?
Yes each employed lawyer should complete and submit the declaration in appendix B.
8. Can you clarify what you mean by client accounts?
Client accounts are the bank accounts in your name (firm or lawyer) that hold funds from your clients and not your own.
9. In the number of clients should we include the once off clients that are represented in the court for a minor traffic violation?
Yes all your clients that you deal with (invoice) should be included.
10. What is FACTIVA and where can someone find it?
FACTIVA is one of the many companies that have databases for screening purposes. There are also companies that you can οutsource your screening function, they offer such services on a continuous basis and let you know of findings about your clients whenever such findings happen.
11. How can I know if one of my clients is high risk?
You should evaluate your clients relative to their money laundering risks and categorize them accordingly.