Renewed identification or ascertainment

If the contracting party has been identified by the financial intermediary, then the obligation set out under Art. 3 GwG is essentially deemed to have been fulfilled.

However, if doubts arise during the further course of the business relationship about the identity of the contracting party or about the beneficial owner, then the financial intermediary must repeat the corresponding measures. In practice, this tends to be triggered by doubts about the identity of the beneficial owner. Frequent clues are:

  • the accountholder and the beneficiary of deposits differ
  • authorised representatives perform transactions instead of the contracting party
  • the scope and the value of the transactions are incompatible with the personal and economic circumstances of the contracting party.


In the case of redeemable policies, insurers must once again ascertain the identity of the beneficial owner (Art. 5 Para. 2 GwG), if:

  • in the event of an insurance claim or in the event of redemption
  • the person entitled to the benefit does not correspond to the person at the time of the conclusion of the insurance contract (e.g. in the event of an assignment).

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