1. The designated thresholds for transactions are as follows:
   • Casinos (under Recommendation 22) - USD/EUR 3,000
   • For dealers in precious metals and dealers in precious stones when engaged in any cash transaction (under Recommendations 22 and 23) - USD/EUR 15,000.

   Financial transactions above a designated threshold include situations where the transaction is carried out in a single operation or in several operations that appear to be linked.

2. The Interpretive Notes that apply to financial institutionsFinancial institutions means any natural or legal person who conducts as abusiness one or more of the following activities or operations for or on behalf of a customer:
   1) Acceptance of deposits and other repayable funds from the public.
   2) Lending.
   3) Financial leasing.
   4) Money or value transfer services.
   5) Issuing and managing means of payment (e.g. credit and debit cards,cheques, traveller's cheques, money orders and bankers' drafts, electronic money).
   6) Financial guarantees and commitments.
   7) Trading in:
   a) money market instruments (cheques, bills, certificates of deposit, derivatives etc.);
   b) foreign exchange;
   c) exchange, interest rate and index instruments;
   d) transferable securities;
   8) Participation in securities issues and the provision of financial services related to such issues.
   9) Individual and collective portfolio management.
   11) Otherwise investing, administering or managing funds or money on behalf of other persons.
   12) Underwriting and placement of life insurance and other investment related insurance.
   13) Money and currency changing.
   are also relevant to DNFBPs, where applicable. For the purposes of R.23, the requirements referring to ‘financial groups’ in R.18 apply to DNFBP groups operating under the same structure as financial groups. In addition, countries should consider applying the requirements for group-wide programmes to DNFBPs operating in other structures sharing common ownership, management or compliance control to the extent that those structures could better mitigate ML/TF risks by applying group-wide programmes. The type and extent of measures to be taken should be appropriate to the business conducted, the risk of money laundering and terrorist financing and the size of the business. For example, as set out in INR.18, countries may determine the scope and extent of information sharing, based on the sensitivity of the information, and its relevance to AML/CFT risk management.
3. To comply with Recommendations 22 and 23, countries do not need to issue laws or enforceable means that relate exclusively to lawyers, notaries, accountants and the other designated non-financial businesses and professions, so long as these businesses or professions are included in laws or enforceable means covering the underlying activities.

INTERPRETIVE NOTE TO RECOMMENDATION 22 (DNFBPS - CUSTOMER DUE DILIGENCE)

1. Real estate agentsFor the purposes of Recommendations 14 and 16, agent means any natural or legal person providing MVTS on behalf of an MVTS provider, whether by contract with or under the direction of the MVTS provider. should For the purposes of assessing compliance with the FATF Recommendations, the word should has the same meaning as must. comply with the requirements of Recommendation 10 with respect to both the purchasers and vendors of the property Property means assets of every kind, whether corporeal or incorporeal, moveable or immoveable, tangible or intangible, and legal documents or instruments evidencing title to, or interest in such assets..
2. Casinos should implement Recommendation 10, including identifying and verifying the identity of customers, when their customers engage in financial transactions equal to or above USD/EUR 3,000. Conducting customer identification at the entry to a casino could be, but is not necessarily, sufficient. Countries must require casinos to ensure that they are able to link customer due diligence information for a particular customer to the transactions that the customer conducts in the casino.

1. Competent authoritiesCompetent authorities refers to all public authorities with designated responsibilities for combating money laundering and/or terrorist financing. In particular, this includes the FIU; the authorities that have the function of investigating and/or prosecuting money laundering, associated predicate offences and terrorist financing, and seizing/freezing and confiscating criminal assets; authorities receiving reports on cross-border transportation of currency & BNIs; and authorities that have AML/CFT supervisory or monitoring responsibilities aimed at ensuring compliance by financial institutions and DNFBPs with AML/CFT requirements. SRBs are not to be regarded as a competent authorities. should For the purposes of assessing compliance with the FATF Recommendations, the word should has the same meaning as must. be able to obtain, or have access in a timely fashion to, adequate, accurateis used to describe information that has been verified for accuracy. and up-to-date information on the beneficial ownership and control of companies and other legal persons Legal persons refers to any entities other than natural persons that can establish a permanent customer relationship with a financial institution or otherwise own property. This can include companies, bodies corporate, foundations, anstalt, partnerships, or associations and other relevantly similar entities. (beneficial ownership information*Beneficial ownership information for legal persons is the information referred to in the interpretive note to Recommendation 10, paragraph 5(b)(i). Controlling shareholders as referred to in, paragraph 5(b)(i) of the interpretive note to Recommendation 10 may be based on a threshold, e.g. any persons owning more than a certain percentage of the company (e.g. 25%).) that are created*References to creating a legal person, include incorporation of companies or any other mechanism that is used. in the countryAll references in the FATF Recommendations to country or countries apply equally to territories or jurisdictions., as well as those that present ML/TF risks and have sufficient links*Countries may determine what is considered a sufficient link on the basis of risk. Examples of sufficiency tests may include, but are not limited to, when a company has permanent establishment/branch/agency, has significant business activity or has significant and ongoing business relations with financial institutions or DNFBPs, subject to AML/CFT regulation, has significant real estate/other local investment, employs staff, or is a tax resident, in the country. with their country (if they are not created in the country). Countries may choose the mechanisms they rely on to achieve this objective, although they should also comply with the minimum requirements set out below. Countries should utilise a combination of mechanisms to achieve the objective.
2. As part of the process described in paragraph 1 of ensuring that there is adequate transparency regarding legal persons, countries should have mechanisms that:
   1. identify and describe the different types, forms and basic features of legal persons Legal persons refers to any entities other than natural persons that can establish a permanent customer relationship with a financial institution or otherwise own property. This can include companies, bodies corporate, foundations, anstalt, partnerships, or associations and other relevantly similar entities. in the country.
   2. identify and describe the processes for: (i) the creation of those legal persons; and (ii) the obtaining and recording of basic and beneficial ownership information;
   3. make the above information publicly available; and
   4. assess the money laundering and terrorist financing Terrorist financing is the financing of terrorist acts, and of terrorists and terrorist organisations. risks All references to risk refer to the risk of money laundering and/or terrorist financing. This term should be read in conjunction with the Interpretive Note to Recommendation 1. associated with different types of legal persons created in the country, and take appropriate steps to manage and mitigate the risks that they identify; and
   5. assess the money laundering and terrorist financing risks to which their country is exposed, associated with different types of foreign-created legal persons, and take appropriate steps to manage and mitigate the risks that they identify*This could be done through national and/or supranational measures. These could include requiring beneficial ownership information on some types of foreign-created legal persons to be held as set out under paragraph 7..

1. BASIC INFORMATION
   3. In order to determine who the beneficial ownersBeneficial owner refers to the natural person(s) who ultimately owns or controls a customer and/or the natural person on whose behalf a transaction is being conducted. It also includes those persons who exercise ultimate effective control over a legal person or arrangement. of a company*Recommendation 24 applies to all forms of legal persons. The requirements are described primarily with reference to companies, but similar requirements should be applied to other types of legal person, taking into account their different forms and structures - as set out in Section E. are, competent authoritiesCompetent authorities refers to all public authorities with designated responsibilities for combating money laundering and/or terrorist financing. In particular, this includes the FIU; the authorities that have the function of investigating and/or prosecuting money laundering, associated predicate offences and terrorist financing, and seizing/freezing and confiscating criminal assets; authorities receiving reports on cross-border transportation of currency & BNIs; and authorities that have AML/CFT supervisory or monitoring responsibilities aimed at ensuring compliance by financial institutions and DNFBPs with AML/CFT requirements. SRBs are not to be regarded as a competent authorities. will require certain basic information about the company, which, at a minimum, would include information about the legal ownership and control structure of the company. This would include information about the status and powers of the company, its shareholders and its directors.
   4. All companies created in a countryAll references in the FATF Recommendations to country or countries apply equally to territories or jurisdictions. should be registered in a company registry.*"Company registry" refers to a register in the country of companies incorporated or licensed in that country and normally maintained by or for the incorporating authority. It does not refer to information held by or for the company itself. Whichever combination of mechanisms is used to obtain and record beneficial ownership information (see section B), there is a set of basic information on a company that needs to be obtained and recorded by the company*The information can be recorded by the company itself or by a third person under the company's responsibility. as a necessary prerequisite. The minimum basic information to be obtained and recorded by a company should be:
      1. company name, proof of incorporation, legal form and status, the address of the registered office, basic regulating powers (e.g. memorandum & articles of association), a list of directors, and unique identifier such as a tax identification number or equivalent (where this exists)*This information should be made public, as set out in paragraph 11.; and
      2. a register of its shareholders or members, containing the names of the shareholders and members and number of shares held by each shareholder*This is applicable to the nominal owner of all registered shares. and categories of shares (including the nature of the associated voting rights).
   5. The company registry*Or another public body in the case of a tax identification number. should record all the basic information set out in paragraph 4(a) above.
   6. The company should maintain the basic information set out in paragraph 4(b) within the countryAll references in the FATF Recommendations to country or countries apply equally to territories or jurisdictions., either at its registered office or at another location notified to the company registry. However, if the company or company registry holds beneficial ownership information within the country, then the register of shareholders need not be in the country, provided that the company can provide this information promptly on request.
2. BENEFICIAL OWNERSHIP INFORMATION
   7. Countries should follow a multi-pronged approach in order to ensure that the beneficial ownership of a company can be determined in a timely manner by a competent authority. Countries should decide, on the basis of risk, context and materiality, what form of registry or alternative mechanisms they will use to enable efficient access to information by competent authorities, and should document their decision. This should include the following:
      1. Countries should require companies to obtain and hold adequate, accurate and up-to-date information on the company’s own beneficial ownership; to co-operate with competent authorities to the fullest extent possible in determining the beneficial owner, including making the information available to competent authorities in a timely manner; and to co-operate with financial institutions/DNFBPs to provide adequate, accurate and up-to-date information on the company’s beneficial ownership information;
      2. (i) Countries should require adequate, accurate and up-to-date information on the beneficial ownership of legal persons to be held by a public authority or body (for example a tax authority, FIU, company registry, or beneficial ownership registry). Information need not be held by a single body only*A body could record beneficial ownership information alongside other information (e.g. basic ownership and incorporation information, tax information), or the source of information could take the form of multiple registries (e.g. for provinces or districts, for sectors, or for specific types of legal person such as NPOs), or of a private body entrusted with this task by the public authority.;
      3. (ii) Countries may decide to use an alternative mechanism instead of (b)(i) if it also provides authorities with efficient access to adequate, accurate and up-to-date BO information. For these purposes reliance on basic information or existing information alone is insufficient, but there must be some specific mechanism that provides efficient access to the information;
      4. Countries should use any additional supplementary measures that are necessary to ensure the beneficial ownership of a company can be determined; including for example information held by regulators or stock exchanges; or obtained by financial institutions and/or DNFBPs in accordance with Recommendations 10 and 22*Countries should be able to determine in a timely manner whether a company has or controls an account with a financial institution within the country..
   8. All the persons, authorities and entities mentioned above, and the company itself (or its administrators, liquidators or other persons involved in the dissolution of the company), should maintain the information and records referred to for at least five years after the date on which the company is dissolved or otherwise ceases to exist, or five years after the date on which the company ceases to be a customer of the professional intermediary or the financial institution.
3. TIMELY ACCESS TO ADEQUATE, ACCURATE AND UP-TO-DATE INFORMATION

   9. Countries should have mechanisms that ensure that basic information and beneficial ownership information, including information provided to the company registry and any available information referred to in paragraph 7, is adequate, accurate and up to date.

      Adequate information is information that is sufficient to identify*Examples of information aimed at identifying the natural person(s) who are the beneficial owner(s) include the full name, nationality(ies), the full date and place of birth, residential address, national identification number and document type, and the tax identification number or equivalent in the country of residence. the natural person(s) who are the beneficial owner(s), and the means and mechanisms through which they exercise beneficial ownership or control.

      Accurate information is information, which has been verified to confirm its accuracy by verifying the identity and status of the beneficial owner using reliable, independently sourced/obtained documents, data or information. The extent of verification measures may vary according to the specific level of risk.

      Countries should consider complementary measures as necessary to support the accuracy of beneficial ownership information, e.g. discrepancy reporting.

      Up-to-date information is information which is as current and up-to-date as possible, and is updated within a reasonable period (e.g. within one month) following any change.

   10. Competent authorities, and in particular law enforcement authorities and FIUs, should have all the powers necessary to be able to obtain timely access to the basic and beneficial ownership information held by the relevant parties, including rapid and efficient access to information held or obtained by a public authority or body or other competent authority on basic and beneficial ownership information, and/or on the financial institutions or DNFBPs which hold this information. In addition, countries should ensure public authorities at national level and others as appropriate have timely access to basic and beneficial ownership information on legal persons in the course of public procurement.
   11. Countries should require their company registry to facilitate timely access by financial institutionsFinancial institutions means any natural or legal person who conducts as abusiness one or more of the following activities or operations for or on behalf of a customer:
       1) Acceptance of deposits and other repayable funds from the public.
       2) Lending.
       3) Financial leasing.
       4) Money or value transfer services.
       5) Issuing and managing means of payment (e.g. credit and debit cards,cheques, traveller's cheques, money orders and bankers' drafts, electronic money).
       6) Financial guarantees and commitments.
       7) Trading in:
       a) money market instruments (cheques, bills, certificates of deposit, derivatives etc.);
       b) foreign exchange;
       c) exchange, interest rate and index instruments;
       d) transferable securities;
       8) Participation in securities issues and the provision of financial services related to such issues.
       9) Individual and collective portfolio management.
       11) Otherwise investing, administering or managing funds or money on behalf of other persons.
       12) Underwriting and placement of life insurance and other investment related insurance.
       13) Money and currency changing.
       , DNFBPs and other countries' competent authoritiesCompetent authorities refers to all public authorities with designated responsibilities for combating money laundering and/or terrorist financing. In particular, this includes the FIU; the authorities that have the function of investigating and/or prosecuting money laundering, associated predicate offences and terrorist financing, and seizing/freezing and confiscating criminal assets; authorities receiving reports on cross-border transportation of currency & BNIs; and authorities that have AML/CFT supervisory or monitoring responsibilities aimed at ensuring compliance by financial institutions and DNFBPs with AML/CFT requirements. SRBs are not to be regarded as a competent authorities. to the public information they hold, and, at a minimum to the information referred to in paragraph 4(a) above. Countries should also consider facilitating timely access by financial institutions Financial institutions means any natural or legal person who conducts as abusiness one or more of the following activities or operations for or on behalf of a customer:
       1) Acceptance of deposits and other repayable funds from the public.
       2) Lending.
       3) Financial leasing.
       4) Money or value transfer services.
       5) Issuing and managing means of payment (e.g. credit and debit cards,cheques, traveller's cheques, money orders and bankers' drafts, electronic money).
       6) Financial guarantees and commitments.
       7) Trading in:
       a) money market instruments (cheques, bills, certificates of deposit, derivatives etc.);
       b) foreign exchange;
       c) exchange, interest rate and index instruments;
       d) transferable securities;
       8) Participation in securities issues and the provision of financial services related to such issues.
       9) Individual and collective portfolio management.
       11) Otherwise investing, administering or managing funds or money on behalf of other persons.
       12) Underwriting and placement of life insurance and other investment related insurance.
       13) Money and currency changing.
       and DNFBPs to information referred to in paragraph 4(b) above and to beneficial ownership information held pursuant to paragraph 7 above, and could consider facilitating public access to this information.
4. OBSTACLES TO TRANSPARENCY
   12. Countries should take measures to prevent and mitigate the risk of the misuse of bearer shares and bearer share warrants*Or any other similar instruments without traceability. by prohibiting the issuance of new bearer shares and bearer share warrants; and, for any existing bearer shares and bearer share warrants, by applying one or more of the following mechanisms within a reasonable timeframe*These requirements do not apply to newly issued and existing bearer shares or bearer share warrants of a company listed on a stock exchange and subject to disclosure requirements (either by stock exchange rules or through law or enforceable means) which impose requirements to ensure adequate transparency of beneficial ownership.:
       1. converting them into a registered form; or
       2. immobilising them by requiring them to be held with a regulated financial institution or professional intermediary, with timely access to the information by the competent authorities; and
       3. during the period before (a) or (b) is completed, requiring holders of bearer instruments to notify the company, and the company to record their identity before any rights associated therewith can be exercised.
   13. Countries should take measures to prevent and mitigate the risk of the misuse of nominee shareholding and nominee directors, by applying one or more of the following mechanisms:
       1. requiring nominee shareholders and directors to disclose their nominee status and the identity of their nominator to the company and to any relevant registry, and for this information to be included in the relevant register, and for the information to be obtained, held or recorded by the public authority or body or the alternative mechanism referred to in paragraph 7. Nominee status should be included in public information;
       2. requiring nominee shareholders and directors to be licensed*A country need not impose a separate licensing or registration system with respect to natural or legal persons already licensed or registered as financial institutions or DNFBPs (as defined by the FATF Recommendations) within that country, which, under such license or registration, are permitted to perform nominee activities and which are already subject to the full range of applicable obligations under the FATF Recommendations., for their nominee status and the identity of their nominator to be obtained, held or recorded by the public authority or body or alternative mechanism referred to in paragraph 7 and for them to maintain information identifying their nominator and the natural person on whose behalf the nominee is ultimately acting*Identifying the beneficial owner in situations where a nominee holds a controlling interest or otherwise exercises effective control requires establishing the identity of the natural person on whose behalf the nominee is ultimately, directly or indirectly, acting., and make this information available to the competent authorities upon request*For intermediaries involved in such nominee activities, reference should be made to R.22 and R.28 in fulfilling the relevant requirements.;or
       3. enforcing a prohibition of the use of nominee shareholders or nominee directors.
5. OTHER LEGAL PERSONS
   14. In relation to foundations, Anstalt, Waqf*Except in countries where Waqf are legal arrangements under R.25. and limited liability partnerships, countries should take similar measures and impose similar requirements, as those required for companies, taking into account their different forms and structures.
   15. As regards other types of legal persons Legal persons refers to any entities other than natural persons that can establish a permanent customer relationship with a financial institution or otherwise own property. This can include companies, bodies corporate, foundations, anstalt, partnerships, or associations and other relevantly similar entities., countries should take into account the different forms and structures of those other legal persons, and the levels of money laundering and terrorist financing risks associated with each type of legal person, with a view to achieving appropriate levels of transparency. At a minimum, countries should ensure that similar types of basic information should be recorded and kept accurateis used to describe information that has been verified for accuracy. and current by such legal persons, and that such information is accessible in a timely way by competent authoritiesCompetent authorities refers to all public authorities with designated responsibilities for combating money laundering and/or terrorist financing. In particular, this includes the FIU; the authorities that have the function of investigating and/or prosecuting money laundering, associated predicate offences and terrorist financing, and seizing/freezing and confiscating criminal assets; authorities receiving reports on cross-border transportation of currency & BNIs; and authorities that have AML/CFT supervisory or monitoring responsibilities aimed at ensuring compliance by financial institutions and DNFBPs with AML/CFT requirements. SRBs are not to be regarded as a competent authorities.. Countries should review the money laundering and terrorist financing risks associated with such other legal persons Legal persons refers to any entities other than natural persons that can establish a permanent customer relationship with a financial institution or otherwise own property. This can include companies, bodies corporate, foundations, anstalt, partnerships, or associations and other relevantly similar entities., and, based on the level of risk All references to risk refer to the risk of money laundering and/or terrorist financing. This term should be read in conjunction with the Interpretive Note to Recommendation 1., determine the measures that should be taken to ensure that competent authorities have timely access to adequate, accurate and current beneficial ownership information for such legal persons.
6. LIABILITY AND SANCTIONS
   16. There should For the purposes of assessing compliance with the FATF Recommendations, the word should has the same meaning as must. be a clearly stated responsibility to comply with the requirements in this Interpretive Note, as well as liability and effective, proportionate and dissuasive sanctions, as appropriate for any legal or natural person that fails to properly comply with the requirements.
7. INTERNATIONAL COOPERATION
   17. Countries should rapidly, constructively and effectively provide international cooperation in relation to basic and beneficial ownership information, on the basis set out in Recommendations 37 and 40. This should include (a) facilitating access by foreign competent authoritiesCompetent authorities refers to all public authorities with designated responsibilities for combating money laundering and/or terrorist financing. In particular, this includes the FIU; the authorities that have the function of investigating and/or prosecuting money laundering, associated predicate offences and terrorist financing, and seizing/freezing and confiscating criminal assets; authorities receiving reports on cross-border transportation of currency & BNIs; and authorities that have AML/CFT supervisory or monitoring responsibilities aimed at ensuring compliance by financial institutions and DNFBPs with AML/CFT requirements. SRBs are not to be regarded as a competent authorities. to basic information held by company registries; (b) exchanging information on shareholders; and (c) using their powers, in accordance with their domestic law, to obtain beneficial ownership information on behalf of foreign counterparts Foreign counterparts refers to foreign competent authorities that exercise similar responsibilities and functions in relation to the cooperation which is sought, even where such foreign competent authorities have a different nature or status (e.g. depending on the country, AML/CFT supervision of certain financial sectors may be performed by a supervisor that also has prudential supervisory responsibilities or by a supervisory unit of the FIU).. Countries should monitor the quality of assistance they receive from other countries in response to requests for basic and beneficial ownership information or requests for assistance in locating beneficial ownersBeneficial owner refers to the natural person(s) who ultimately owns or controls a customer and/or the natural person on whose behalf a transaction is being conducted. It also includes those persons who exercise ultimate effective control over a legal person or arrangement. residing abroad.