why do I have to fill everything in again from scratch at a new bank
Every bank conducts its own customer due diligence
That is because every bank is required to conduct customer due diligence itself, and that investigation may not be taken over from another bank. This is called the customer due diligence under the Act on the prevention of money laundering and financing of terrorism (Wwft). The previous bank has built up its own file on your company, with its own risk assessment and its own records. A new bank cannot rely on that: they must conduct the customer due diligence independently, even if the questions and answers are virtually identical to what you filled in elsewhere before.
In practice, these are largely the same topics: who are the ultimate beneficial owners of the companyor one of the directors or interested parties a politically exposed person is, or if a sanctions list check is needed, and what the origin of the funds is. Every bank asks those questions in its own format and at its own time, but the underlying facts about your company do not change. That is precisely why it is useful to record those answers once in a supply chain file: not to take over the bank's obligation, but to make filling in each new application faster. See also how ubo data is filled in a questionnaire for the approach that banks expect in this regard.
Where this follows from: the Wwft and the Trade Register
The customer due diligence of the Wwft requires every bank to determine the identity and risks of a client itself, without being able to rely on investigation by another institution without its own verification. Some of the data, such as the directors and the registration of the company, are set out in the Trade Register on the basis of the Trade Register Act 2007 — but that register does not replace customer due diligence, it is merely one of the sources that the bank consults.
What this is based on
- Trade Register Act 2007 — the data recorded for each company
- Act on the prevention of money laundering and the financing of terrorism — client due diligence
- Directive (EU) 2022/2464 (CSRD)
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.