The Superintendences of Market and Intermediary Relations (SMI) and Institutional Investor Relations (SIN) of the Securities Commission (CVM) released, on November 29, 18, Circular Letter CVM/SMI/SIN 03/2018, in order to guide Brazilian intermediaries on the simplified registration of non-resident investors when the respective foreign intermediary has not provided all the information necessary for the application of the "Know Your Client Policy"(Know Your Client).
The 'Know your Customer' Policy should be adopted, minimally, by the Brazilian intermediary from the:
(i) identification of the client (RG number or the respective CNPJ registration number - in the case of non-resident investors, regardless of the use of simplified registration, such information must also include the CVM code number);
(ii) collection of all registration information, pursuant to Annex I of CVM Instruction 301/99ç
(iii) conducting ongoing due diligence to: (a) verify the accuracy of the information, (b) collect supplementary information (when applicable), and (c) keep it updated; and
(iv) evidence of efforts to identify the final beneficiary, where applicable.
To access the full CVM/SMI/SIN Circular Letter 03/2018, click here.
Barcellos Tucunduva Advogados remains at your disposal to clarify any doubts related to this matter.
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