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General terms and conditions and privacy statement

Thorough client acceptance requires more than identification and verification: it also includes the engagement letter, general terms and conditions, and privacy statement. However, these documents are often sent separately and manually by email. There is a smarter way.

Keeping track of documents and approvals

With RegLab, you can send the engagement letter, general terms and conditions, and privacy statement all at once, along with the mandatory AML client identification. This prevents separate communications and ensures a complete client matter from the start. It is also convenient for your client to receive all documents clearly organised at the same time.

Has the client filled in all the necessary information for the client screening? If so, they can immediately approve the engagement letter/subscription agreement, general terms and conditions, and privacy statement. Sending the latter two is optional, but often recommended.

The client receives everything in a clear format and in the correct language. These documents can be uploaded centrally within RegLab. This way, Dutch clients receive the Dutch version and Spanish clients receive the Spanish version. This keeps the process professional and efficient.

By automating the sending process, you benefit from a professional image towards the client. In addition, RegLab automatically records when and what the client has agreed to. This is important for your matter, especially if there is a dispute later on about the agreements made.

Are general terms and conditions mandatory in terms of AML?

No. AML only requires an engagement letter, not general terms and conditions. However, it is wise to use them. They provide clarity about your firm's rules and can prevent many discussions. Even though it is not mandatory, you can avoid a lot of hassle with clients by using them. This is because you are clear about the rules of the firm with regard to the services to be provided. You can fall back on this if you have a disagreement with a client.

What if the terms and conditions change?

Are your firm's general terms and conditions changing? Simply upload the new version to RegLab. New clients will automatically receive the updated terms and conditions.

Please note: you cannot apply amended terms and conditions retroactively to previous agreements. You will need to obtain the client's approval again. For existing clients, you can therefore resend the general terms and conditions from RegLab, with a request for approval.

Approving the order confirmation

What should be included in the privacy statement in accordance with AML regulations?

The GDPR requires you to explain in your privacy statement why and on what grounds you process personal data. In the context of AML, you do so on the basis of a legal obligation. Make sure this is explicitly stated in the statement, including what data you process, how long you retain it and with whom you may share it (for example, when reporting to the FIU or during an audit by the supervisory authority).

Can you include the privacy statement in the general terms and conditions?

No, you cannot “hide” a privacy statement in the general terms and conditions. The GDPR stipulates that clients must be clearly informed about what data you collect and why. The content of the privacy statement must also be easily accessible. If you have to search for it in another document, it is not considered accessible. That is why the privacy statement must always be provided separately.

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