Anti money laundering policy

Since 2 February 2004, lawyers have been subject to certain provisions of the anti-money laundering legislation. By (i) the Act of 18 September 2017 on the Prevention of Money Laundering and Terrorist Financing and on the Restriction of the Use of Cash and (ii) Section III.1.2 of the Code of Ethics for Lawyers, our firm is required to establish and implement an anti-money laundering policy.

Depending on the nature of the services our firm provides to you, we may be required to strictly comply with anti-money laundering and anti-terrorist financing laws and bar regulations. In such a case, we are mainly bound by an enhanced duty of identification and vigilance towards our client, its representatives and agents. In this context, we are obliged to collect information on the identity, characteristics of the client and purpose and nature of the transaction and, for this purpose, we may carry out checks using external electronic databases.

This procedure requires the cooperation of the client, who undertakes to provide the requested information upon first request. Clients working under the form of a legal person or other legal construction should disclose who is the ultimate beneficiary behind this legal form. The client should also communicate any change that may affect his or her status. A client who refuses to provide information, after it has been requested, will be informed that our services cannot be started or will be stopped immediately. In addition, the anti-money laundering legislation and Codex Deontology require the lawyer to report possible suspicions of money laundering or terrorist financing in which the client is allegedly involved to the Chair of the Bar in certain circumstances. Our firm is not liable to the client for the consequences of any reporting made in good faith.