Association duties

In addition to the due diligence duty and the duty to report which you must fulfil as a financial intermediary in accordance with the AMLA and the Regulations of SRO PolyReg, members of SRO PolyReg are subject to a training obligation in accordance with Art. 8 AMLA and must comply with additional association duties such as the duty to report changes. The individual duties are regulated in the Regulations and the Statutes of SRO PolyReg and must be complied with in order to maintain membership.

Within the scope of their membership, financial intermediaries are subject to a comprehensive duty to report changes and must report to the SRO all changes in the conditions that led to their membership without delay. Changes are to be reported exclusively by means of the form to report changes.

The duty to report changes concerns, a.o.:

  • Any change of address or legal domicile
  • Any change of the firms name or of the form of incorporation
  • Changes of shareholders or owners
  • Any change of the executors or responsible persons
  • Changes of the staff carrying out AMLA-relevant tasks
  • Opening of a criminal procedure or administrative procedure against the member or its executives.
  • Changes in the scope of AMLA-relevant business offered.
  • Any writ of execution against the member

In addition, the members have an unlimited disclosure duty towards SRO PolyReg with regard to all AMLA-relevant facts and events.

Finally, the members have a duty to cooperate, namely in the regular AMLA audits, but also in terms of permanent availability and compliance with instructions from SRO PolyReg.

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