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Hungary has introduced a UBO register in line with the EU’s 4th Anti-Money Laundering Directive by way of Act XLIII of 2021 on the Establishment and Operation of the Data Reporting Background for the Identification Tasks of Financial and Other Service Providers (“Act”). Certain provisions of the Act will come into force at a later date.

On 2 November 2021 the Austrian Financial Market Authority (FMA) published its long-awaited amended Online Identification Regulation (Online-Identifikationsverordnung, "Online-IDV"). The FMA herewith enables financial service providers subject to the KYC obligations of the Financial Market Anti-Money Laundering Law (Finanzmarkt-Geldwäschegesetz; "FM-GwG") to use purely biometrical processes for remote identification of new customers. Biometrical identification processes are all procedures for online customer identification where the entire or parts of the online identification are carried out by an automated electronic procedure without the involvement of employees – there is no need for personal contact in the whole remote identification process anymore.

Until November 2021, crowdfunding activities (investment-based or lending-based) have not benefited from a dedicated regime and may interfere with the EU banking and financial services rules, triggering ultimately significant risks to all parties involved.

How certain is the development of the ever-increasing use and application of electronic documents, especially in terms of legalization of documents for international legal transactions?

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