The basic customer data such as name and actual residential address (domicile) are updated. Up-to-date confirmation on the beneficial ownership of the incorporated assets is also required. Optionally, information on employer, profession and gross annual income can be updated or requested for private customers, as this data is collected as part of a standard procedure when a new account is opened. As part of our obligation to update customer data, this information is now also requested from customers who already have a business relationship with PostFinance, and who were not asked for this information at the time of opening the business relationship. A complete customer profile (KYC) allows PostFinance to make a more straightforward assessment in the overall context if there is an anomaly.
In the case of business customers, data that is also requested when opening an account includes (in addition to the registered office and the purpose of the company) data on the number of employees and, optionally, data on the annual turnover. This is data that is good for the KYC, and it makes it easier to assess anomalies in transaction behaviour in the best way possible in the overall context. In particular, the indication of the number of employees allows PostFinance to assess whether a company is a domiciliary company or not (art. 39 CDB20) Additionally, the persons controlling operationally active legal entities must provide a declaration, or information previously provided to PostFinance must be confirmed. The “form K” used for this purpose was introduced in 2016 (cf. art. 20 ff. CDB20). As part of the updating of customer data, the declaration must now also be made by all customers who opened their banking relationship prior to the introduction of the obligation. Up-to-date confirmation on the beneficial ownership of the incorporated assets is also required.