Full Check Process Guidelines

Things to know before submitting documents for the Full-Check

Here is a list of documents you may be requested to provide during the AML Full-Check. 

• Application Form (onboarding clients only)

The Onboarding Specialist will provide you with the Application Pack, attached to the email. This form must be filled in, printed out, signed, and scanned or photographed Please note that all the fields must be filled in, otherwise the form cannot be accepted, and you will have to fill it again and resubmit it. If your answer to the question asked in the form is “YES”, you must provide details of the information requested. If you are completing the Corporate Application Pack, it must include information about all company’s directors, UBOs, & Signatories.

• IBAN information (onboarding clients only)

We need to know whether the Client requires an IBAN and if so, in which currencies.
At the moment you can choose between EUR and GBP, or select both. 

• Contact information

Required Individual contacts: e-mail, phone number.

Required Corporate contacts: e-mail, phone number, website, physical address (as it may differ from registered address).
Corporate and personal contacts must differ, as we create separate accounts for the company and each individual.

• Set of Registration Documents (corporate entities only)

These documents help us understand: date and place of registration, directors, UBOs, shareholders, regulations, etc.
Please, provide a set of registration documents according to your country (e.g., Certificate of Incorporation, Certificate of Registration, Memorandum and Articles of Association, Certificate of Directors, Certificate of Registered Office, Certificate of Shareholders).

1. For companies registered outside of the EU, documents must be apostilled.
2. For companies registered in the EU, documents must be notarized.
3. A copy of the document must be notarized in any case.
4. Documents must be in English or with the notarized translation. The translation must be attached along with the original.

• Certificate of Good Standing AND Certificate of Incumbency; OR Excerpt from Registry (corporate entities only)

Please provide a Certificate of Good Standing and Incumbency in conjunction or an Excerpt from the Registry.

1. Documents must be issued within the last 3 months.
2. For companies registered outside of the EU, documents must be apostilled.
3. For companies registered in the EU, documents must be notarized.
4. A copy of the document must be notarized in any case.
5. Documents must be in English or with the notarized translation. The translation must be attached along with the original.

A Certificate of Incumbency must include the company’s name, registration number, registered office, and all current directors, as well as the shareholders and the number of shares they own.

An Excerpt from the Registry must include the same information as the Certificate of Incumbency, as well as the date and place of incorporation and the company’s authorized business activities.

• Agreements With Partners (For corporate entities only)

Please provide 1-2 agreements with the company's business partners. It can be a Marketing Services Agreement between both parties (customer and a company); a Security Services Agreement; an IT Consulting Website Maintenance Agreement, basically, any type of agreement with partners that you have that is valid and signed by both parties. 

If the company is new, drafts of the agreements will be sufficient. 

Agreements must be in English or with an authorized translation.

• Detailed Description of Business (For corporate entities only) 

Please provide a detailed description of the business activities the company is involved in and how the business is handled in general. We need to know what products/services the company offers and how the company attracts clients.

We accept text descriptions of up to ten sentences, a business plan, or a presentation.

• Cash Flow (For corporate entities only)

Please, provide a schedule with sources of the company’s incoming and outgoing funds. The chart must include the amounts in numbers or percentages, counterparties countries, counterparties companies’ names and their websites.

If the company is new, you should provide an estimated cash flow with approximate amounts.

• Corporate Utility Bill or Rental Agreement. (For corporate entities only)

Please provide a corporate Utility Bill (water, gas, electricity, landline). The Utility Bill must be issued within the last three months. Documents must be in English or with an authorized translation.

If the landlord is covering the Utility Bills, please provide the Utility Bill addressed to the landlord and a lease agreement that details this arrangement. The lease agreement must be valid and must include the start and end dates of the rent.

We do not accept cell phone bills, invoices, corporate bank statements or bank references as proof of the company’s address.       

• Personal Proof of Address 

Utility Bill (water, gas, electricity, landline), Bank Statement, or a Bank Reference. The documents must be issued within the period of the last three months and must be in English or with an authorized translation. 

If you are completing a corporate application, we also require proof of the residential address of all the parties having control or ownership of the company, (directors, shareholders, UBO’s). 

Any phone or internet bills and Invoices cannot be accepted.

• AML/KYC/Risk Policy, Wolfsberg Group Questionnaire (For corporate financial entities)

Please, provide an AML/KYC/Risk policy if your company is a financial entity. The policy should include the company's name, drafter’s name and position, and the signature of a responsible person.

If you hold a fuller document compared to one embedded on the corporate website, please provide that document. 

You will also be provided with the Wolfsberg Group Questionnaire that needs to be printed out, filled in and signed. 

• CV

Please, provide a CV/resume for all directors, shareholders, and UBOs of the company. The CV must be up-to-date and include contact information, work experience (companies, positions, periods of time), education, and skills.

• Financial Statement for last year (for corporate clients).

We need to know the company’s income, expenses, and profits for the last year.

Must be in English. Not needed for companies younger than 1 year.

• Group Structure (for corporate clients).

This is requested if there is more than 1 company in the structure. We need to know the connection between the main company, its' management, shareholders, and UBOs.

• Bank Statement for the last 6 months (for corporate clients).

We need to see a statement from the bank, showing the company’s incomings and outgoings for the last 6 months. Must be in English or with the notarized translation.

• Bank Statement/Bank Reference (for corporate clients).

We need to know If the entity has accounts with other banks. This information can be found in the Application Pack DDQ. If yes, we need a Bank Statement or Bank reference from these banks. Must be in English or with an authorized translation.

• Source of Wealth of UBO. 

We require a document showing the UBO’s source of wealth. It could be a payslip, tax reference, or another document proving ownership of physical or tangible assets. Must be in English or with the notarized translation, and issued within the last 3 months.