Checklist: assessing the legacy of a long-standing clientele
- Identify the business relationships opened before the current obligations came into force and verify that their documentation has been brought up to date.
- Check the identification of the beneficial owners of older asset-holding structures, in particular domiciliary companies.
- Verify the tax compliance of foreign clients’ assets and document the steps taken to obtain it.
- Examine the origin of the funds contributed when the older relationships were opened and on the occasion of significant later contributions.
- Identify the clients who are or have been politically exposed persons and apply the enhanced due diligence measures required.
- Document the decisions to maintain or close relationships presenting particular risks.
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.