Corporate Client Verification Requirements
1. Purpose
This policy (Ref: COMP-KYC-003) sets out the identification and verification requirements for corporate and legal entity clients. It ensures the Bank meets its obligations under AMLD6, the FATF Recommendations, and applicable national legislation regarding the transparency of legal persons and arrangements.
2. Scope
This policy applies to all legal entities seeking to establish a business relationship with the Bank, including but not limited to:
- Limited liability companies and public limited companies.
- Partnerships (general, limited, and limited liability).
- Trusts and foundations.
- Unincorporated associations and non-profit organisations.
- Government entities and state-owned enterprises.
- Special purpose vehicles (SPVs) and holding structures.
3. Entity Identification Requirements
The following information must be obtained for every corporate client:
| Data Element | Required Documentation |
|---|---|
| Full legal name | Certificate of incorporation or equivalent |
| Registration number | Commercial register extract (not older than 12 months) |
| Registered office address | Commercial register extract or articles of association |
| Principal place of business | Utility bill, lease agreement, or commercial register |
| Legal form and status | Certificate of good standing or equivalent (not older than 6 months) |
| Constitutional documents | Articles of association / memorandum of association / partnership deed |
| Directors and officers | Board resolution, company register filing |
| Authorised signatories | Board resolution or power of attorney |
| Nature of business | Business description, financial statements, company website |
| Tax identification number | Tax registration certificate or CRS self-certification |
4. Beneficial Ownership
4.1 Identification Threshold
The Bank must identify all natural persons who directly or indirectly own or control 25% or more of the shares, voting rights, or ownership interest of the entity. Where the entity is part of a multi-layered ownership structure, the Bank must look through each layer to identify the ultimate beneficial owner(s).
4.2 Control Without Ownership
Where no natural person meets the 25% ownership threshold, the Bank must identify the natural person(s) who exercise control through other means, such as:
- Power to appoint or remove the majority of the board of directors.
- Significant influence through shareholder agreements or other arrangements.
- Control through nominee arrangements, trusts, or similar structures.
If no beneficial owner can be identified through the above, the Bank must identify and verify the identity of the senior managing official(s) of the entity.
4.3 Verification of Beneficial Owners
Each identified beneficial owner must be verified to the same standard as an individual client (refer to COMP-KYC-002). Identity documents, proof of address, and source of wealth documentation may be required.
5. Complex Structures
For entities with complex or opaque ownership structures, the following additional measures apply:
- A detailed organisational chart must be obtained and verified, showing all intermediate entities up to the ultimate beneficial owner(s).
- Incorporation documents and commercial register extracts must be obtained for each material intermediate entity.
- The rationale for the structure must be understood and documented.
- Enhanced Due Diligence must be applied in accordance with COMP-AML-004.
6. Trusts and Foundations
For trusts, the Bank must identify and verify:
- The settlor(s).
- The trustee(s).
- The protector (if any).
- The beneficiaries or class of beneficiaries.
- Any natural person exercising effective control over the trust.
For foundations, the equivalent roles (founder, council members, beneficiaries) must be identified and verified.
7. Timing and Escalation
Corporate KYC must be completed before the establishment of the business relationship. The KYC Operations Team must complete quality assurance checks within ten (10) business days of submission. If outstanding documentation is not received within thirty (30) calendar days, the account must be restricted and escalated to the Compliance Department.
8. Review
This policy is reviewed annually. Next review: Q2 2027.