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Bureau Van Dijk database
AWDC offers free access to the Bureau Van Dijk database to all Belgian registered diamond traders. This enables diamond traders to gather more information about their clients and to verify their KYC information. The database contains, amongst others, the following information for 250 million companies worldwide:
- Identification details
- Sanctions lists
- Politically Exposed Persons lists
- Enforcement lists
- FATF & EU high-risk countries
- Adverse media
- Member state of the Kimberley Process
It makes a risk screening based on the results of the different information that is screened, and as such also helps diamond traders in making an assessment of the potential risks related to the client/the business relationship/the transaction.
Using this database thus helps diamond traders to comply with their AML obligations: in the verification stage of their KYC processes and to conduct a risk analysis of their clients.
Please note that the Bureau Van Dijk database is not the same as MyKYCBank. For more information on MyKYCBank, please consult this page.
Please read the Q&A below to be fully informed on the database and how to use it.
1. Is this tool obligatory?
No. Use of the Bureau Van Dijk database is not mandatory. However, it is mandatory for Belgian diamond traders to identify their clients, to verify their identity and to conduct risk analyses in their client relationship.
In this regard, AWDC offers free access to this database to Belgian diamond traders, to help them comply with these obligations. However, a diamond trader is free to use other databases or sources for verification purposes and for conducting risk analyses as well.
Do keep in mind that the FPS Economy endorses the use of this database for KYC & risk analysis purposes, and that in case of an inspection, you may be asked to prove how you verify your clients’ KYC information and how you make a risk analysis. In such a case, if you use Bureau Van Dijk, you could show your portfolio/search history in the database to demonstrate your screenings.
2. How do I get access?
One can access the Bureau Van Dijk database by logging in via the website www.registereddiamondcompanies.be.
For Belgian registered diamond companies, AWDC provides free access to the database after following a short training on how the database works. If you do not yet have access, you can make an appointment with our AML & Compliance Helpdesk to follow this training and get access.
If you are not a Belgian registered diamond company, but you would like to get access to the database, this is possible but against a certain fee. Please contact our Bureau Van Dijk contact persons Mr. Joost Persyn (firstname.lastname@example.org) or Mrs. Marieke Van Vliet (email@example.com) for more information.
3. Is this a system made especially for the diamond sector?
Bureau Van Dijk services many other sectors, including large banks and corporations which pay large amounts of money to be able to access the system. AWDC also invested a considerable amount in the database of Bureau Van Dijk in order to offer access to all Belgian registered diamond traders for free. For the moment, this is the best system on the market for KYC information.
The system has been customized for Belgian diamond traders, as the database makes a screening against different parameters which are relevant to the diamond sector specifically, e.g. Kimberley Process member states, FATF and EU high-risk countries.
4. Do I also need to use this database for Belgian clients?
If your client is a Belgian registered diamond trader, an outprint of the result page of the company on the website www.registereddiamondcompanies.be is sufficient for KYC purposes.
However, in terms of the risk analysis which diamond traders are supposed to make, it is recommended to use this tool as it can give you indications of possible risks (e.g. director has enforcements, negative media about the company etc.).
For Belgian clients which are not registered as a diamond trader or for private persons, you can use the database as an extra tool of verification.
5. Can everyone see my search results?
No. Your search history is individual and remains anonymous.
If a potential match has been accepted or rejected by another company, it can be seen that another person on the system has checked the potential match (the tick box will be ticked as indication that the match has already been checked), but it is anonymous who has accepted or rejected it.
For example: the system gives a match relating to one of the directors, that he has negative media against him, but another user on the database has checked this information and decided it had to do with a different person carrying a similar name to the director. Therefore, he rejected the match. When you search the same entity, you will see that the risk result is ‘low’ because the initial match has been rejected and see that the box next to the director will be ticked. If you click on the source link, you will still be able to see the information that the initial match related to, and change this (in this case: accept the match, because according to your information, the match is correct). This will then be updated in the system, and the tick box will remain ticked.
In case you get an inspection by the FPS Economy and want to show that you use the Bureau Van Dijk database, you can log in to the system and show your search history. However, they will not be able to see this information unless you show it to them.
6. Do I have to make a print-out of the results?
It is not obligatory to make a print-out of the result page of your searches through the Bureau Van Dijk database. However, it is highly recommended to keep the result pages of the searches that you do, to be able to prove to the FPS Economy that you have taken the necessary verification measures in order to comply with your AML/KYC obligations. You can save the results in your personal portfolio in Bureau Van Dijk, keep a digital copy of the results on your computer or take a print-out.
7. Does this database mean that I don’t have to ask any more documents from my clients and that I don’t have to do a risk analysis anymore?
No. The AML legislation requires you to identify your client and to verify the identity. This database is meant as a verification tool for KYC purposes. It does not contain copies of ID cards nor bylaws, which information you still have to ask from your client.
Also the database is not always complete (for example, it is possible that not all directors, UBOs are published for a certain company and that Bureau Van Dijk thus does not have all information), nor is the information always correct (for example, the directors may have changed but this new information was not shared with the Bureau Van Dijk database by their information providers). Bureau Van Dijk works with local information providers in countries all over the world and the correctness and completeness of the data thus depends on the information they deliver. Of course, this information is updated constantly. If you notice any incorrect or incomplete information, please notify our AML & Compliance Helpdesk (firstname.lastname@example.org or email@example.com) about this. They will contact Bureau Van Dijk, to let them assess the information, contact their local information providers and update the information where appropriate.
The Bureau Van Dijk database can be very helpful to double-check the information provided by your client, for example the names of directors, the shareholder structure, ultimate beneficiaries (UBOs) and to give you more information about the company that you are dealing with, since the company and its directors and UBOs are being matched against sanction lists, PEP lists (Politically Exposed Persons), adverse media, etc. The system will also inform you if your client is located in a country that is part of the Kimberley Process (if so: low risk and it means you can trade in rough diamonds with a company located in that country; if not, it will be indicated as a medium risk and you will not be allowed to trade rough diamonds with this company) and if your client is located in a country that is on the FATF or EU high-risk country list (high risk) or tax haven (medium risk). All this gives you elements to take into account when making a risk analysis. You can thus use the database to perform part of your risk analysis, but using the database does not mean that you need not assess any other potential risks anymore (e.g. related to the payment transaction which the Bureau Van Dijk system does not monitor). The database can give you extra assurance on the company that you are dealing with.
A search in the KYC database is especially helpful when you have a client abroad that has provided you with limited information. An easy way of working with the database, is by sending the information (=the shareholder structure, UBO’s and names of board of directors) you found on the database to your client and ask him to confirm by e-mail if the information is correct.
8. What if I cannot find a company?
It is possible that you cannot find a company in the database.
Please send an e-mail to the AML & Compliance Helpdesk (firstname.lastname@example.org or email@example.com) with all details which you have on the company (company name, address, VAT number, directors, supporting documents etc.). We will try to help you with your search. If the company is not available in the Bureau Van Dijk database, we will pass on all available information to Bureau Van Dijk, to let them contact their local information providers and have the company added to the database.
Thanks to your cooperation, the database will then continue to grow and become more and more useful for the diamond sector.
9. What if the information on a company is incomplete or incorrect?
Bureau Van Dijk works with local information providers in countries all over the world and the correctness and completeness of the data thus depends on the information they deliver. Of course, this information is updated constantly. If you notice any incorrect or incomplete information, please notify our AML & Compliance Helpdesk (firstname.lastname@example.org or email@example.com) about this. They will contact Bureau Van Dijk, to let them assess the information, contact their local information providers and update the information where appropriate.
10. I would like to have access to more detailed financial info, is this possible?
11. Why do I have to answer the AWDC questions before I get my search result? Is this mandatory?
These questions were added just to remind you of other potential risks concerning the transaction. If you can answer all these questions in a positive way, you will notice that your answers will get a green color in your overview page, which means that your transaction is low risk and an extra assurance for you to do the transaction in a safe way. You will have to answer these questions to get your end result. But of course the answers to these questions are purely personal, and for your own use. The answers to these questions only get relevant when you decide to show these results during a control of the Ministry of Economy. But this is at your own discretion.
12. What do the green, orange and red colors mean?
If your search result colors entirely green, this means that the system has found no matches relating to potentially negative or risky information (e.g. sanction lists, PEP lists, negative media etc.). This means also that your client is located in a country that is part of the Kimberley Process, not on the FATF or EU high-risk country list or in a country that is considered a tax haven.
However, do always check if the information is complete. The diamond trader does need to bear in mind that the Bureau Van Dijk result page also turns green when no particular information is found about the company. The green result page can only be considered low risk when all information about the company was actually found on Bureau Van Dijk and checked against sanction lists, PEP lists etc. The diamond trader should therefore check whether the information in the Bureau Van Dijk database is complete (all information on the directors, ultimate beneficial owners etc. is available). In case the information is not complete, the diamond trader tries to obtain the information missing in the database through other channels/searches and make a risk assessment.
If you get an orange result, this means that there is a medium risk. You should assess which information this result relates to, and whether the risk is applicable to your client/your client relationship.
For example, if your client is located in a country that is not part of the Kimberley Process, this will be indicated as a medium risk, because it is not allowed to trade in rough diamonds with these countries. However, if you are trading in polished diamonds, this risk is not relevant to your client relationship.
Certain orange results (for example a match of one of the directors with a PEP, someone on a sanction list, someone who has negative media against them etc.) still need to be verified by you to assess whether the given match is indeed correct. For example, it is possible that the system gives a match for Mr. X who is a director in your client’s company, with a PEP. You should check if it is indeed the same Mr. X that the system gives a match with, because this may be someone with the same or a similar name. It is usually easy to check if it is the same Mr. X since the database contains pictures, information on residence, date of birth, other/previous positions etc.
If the match is applicable (there is indeed a medium risk applicable), you should be extra vigilant and take risk-mitigating measures if possible. For a detailed overview of how to proceed when certain risks are applicable, please consult AWDC’s AML policy (this document can be downloaded through the overview page of the compliance documents on the AWDC website). If you get a red result (for example a match with a sanction list), this is a high risk. Again, you first need to verify the match. If there is indeed a match with an entity on a sanction list, please consult AWDC’s ‘Sanctions & Embargoes Compliance Guide for the Diamond Trade (2019)’ for detailed information on what to evaluate and how to proceed.
13. What if one of the directors or ultimate beneficiaries is on a PEP list? Can I still carry out the transaction?
For PEPs you will get an orange result. You can still do the transaction, but you will have to be extra vigilant. You should in an case take the following measures: (1) obtain permission of the higher management in your company to enter into or continue the business relationship with these persons; (2) take appropriate measures to determine the origin of the funds which are used in the business relationship or transactions with these persons; (3) exercise a stricter supervision on the business relationship and the execution of the transaction.
For a detailed overview of how to proceed when certain risks are applicable, please consult AWDC’s AML policy. This document can be downloaded through the overview page of the compliance documents on the AWDC website.
14. If I don’t like a company, can I make the directors or the UBOs of the company medium or high risk?
No. The information and possible matches in the system are generated by Bureau Van Dijk’s information providers and it is thus not possible to create a match with a medium or high risk outcome yourself.
As explained above (question 3), if the system gives a potential match with certain medium or high risk information and this match is accepted or rejected by a user in the system, this match can later always still be reviewed and changed by another user on the system.