Client Onboarding: Frequently Asked Questions (FAQ)

This FAQ helps you understand why we collect information during the onboarding process. The documents we request are part of our commitment to complying with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. This applies to both regulated and non-regulated clients.

1. General Questions

Q: Why do you need so much information about my company?

A: As a financial services provider, we are legally required to Know Your Client (KYC). We use a risk-based approach to Client Due Diligence (CDD) to prevent money laundering, terrorist financing, and other financial crimes. The information we ask for is mandated by regulatory bodies like the Financial Conduct Authority (FCA) in the UK and the Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg.

Q: What is a Client Risk Rating (CRR)?

A: A CRR is an internal risk score we calculate based on factors like your industry, country of incorporation, ownership structure, and whether any key individuals are Politically Exposed Persons (PEPs). Your CRR determines the level of due diligence we apply—either standard or enhanced.

Q: How long will onboarding take?

A: The timeline varies depending on the complexity of your company's structure and how quickly you submit all required documentation. Simple cases can be completed in a few days, while more complex or high-risk cases may take longer.

Q: Will my information be kept confidential?

A: Absolutely. We adhere to UK GDPR and all relevant data protection laws. Your information is used solely for compliance and onboarding purposes. You can find more details in our Privacy Notice.

Q: Can I start transacting before onboarding is complete?

A: No. According to AML regulations, we must complete the CDD process before we can activate your services.

Q: What happens if a document isn't accepted?

A: We'll let you know the reason (e.g., an expired ID, poor scan quality) and ask you to resubmit. Providing clear, valid, and up-to-date documents from the start will help avoid delays.

Q: What if I don't have all the required documents?

A: Please complete your application and submit all available documents first. This allows us to begin our review and identify any missing information, which enables us to assist you more quickly and avoid unnecessary delays.

Q: How do you verify the documents I submit?

A: We conduct checks to confirm the authenticity and validity of all documents provided. This may include cross-referencing information with official government registers and using third-party verification tools. You can view all attached files in each section of your application and update them as needed before final submission.

2. Company Information & Documents

Q: What company documents are required?

A: You will typically need to provide:

• Certificate of Incorporation (proof of company formation)
• Recent Commercial Register Extract (dated within the last three months, confirming the company is active)
• Articles of Association / Memorandum of Association (your company's governance rules)
• Proof of Business Address (a utility bill, bank statement, or government letter dated within the last 90 days). Additional verification may be needed for higher-risk clients.

Q: What's the difference between Legal Entity Name and Trading Name?

A: Your Legal Entity Name is your company's official registered name. The Trading Name (or "Doing Business As") is the name you use for daily operations. Both are required for regulatory reporting.

Q: Why do you need my company’s ownership structure?

A: We are required to identify the Ultimate Beneficial Owners (UBOs) to comply with financial crime regulations. Ownership charts help us identify the individuals who ultimately control the business.

Q: How should I provide the ownership structure?
A: Please provide an ownership structure chart that clearly sets out:

• All entity names and their country of registration
• Shareholdings/percentages at each level of the structure
• The full chain of ownership through to the ultimate natural persons

If the entity has three or more layers of shareholders, PPRO may require the chart to be independently certified (e.g. by external legal counsel or an auditor).

The level of detail required depends on your company structure:

• For simple structures, a register extract showing individuals who own 25% or more is sufficient.
• For complex structures, you'll need a certified ownership chart that maps all layers back to the individual UBOs.
• For EU-based companies, you must also provide an extract from the national UBO Register (dated within the last month). If this information is already included in your commercial register, please re-submit that document.

Q: What if my business is regulated?

A: If your business is regulated, you must provide the regulator's name (e.g., FCA, CSSF, BaFin), your license or authorisation number, and supporting evidence (e.g., a license extract, Memorandum/Articles of Association). We may also request your internal Financial Crime framework after submission.

3. Key Individuals (Directors, UBOs & Signatories)

Q: Who is considered a "key individual"?

A: Key individuals are those who control or benefit from the company. This includes:

• All managing directors
• All Ultimate Beneficial Owners (25%+)
• All authorised signatories

Q: Why do you need personal details for key individuals?

A: We need details like date of birth, nationality, and country of residence to verify identity, conduct sanctions and PEP screenings, and assess risk.

Q: What documents are required for each key individual?

A: You will need to provide:

• A government-issued photo ID (passport or national ID) that is valid for at least six months.
• Proof of Residential Address (dated within the last 90 days), such as a bank statement, council tax bill, or utility bill. Mobile phone bills are not accepted.

Q: What is an Ultimate Beneficial Owner (UBO)?

A: A natural person who (directly or indirectly) owns or controls 25% or more of shares or voting rights or financial interest (depending on the entity type).

Q: What is a Politically Exposed Person (PEP)?

A: A PEP is someone who holds a prominent public role (like a head of state or a member of parliament), along with their close family members or associates.

Q: Does being a PEP prevent me from being a client?

A: No, but it does require us to conduct Enhanced Due Diligence (EDD), including checks on your Source of Wealth (SoW). This will be required after your application has been submitted.

Q: What is a Power of Attorney (PoA) and when is it needed?

A: A Power of Attorney (PoA) is a legal document in which one person (the "donor") grants another person (the "attorney") the authority to make decisions on their behalf. This is necessary when the person representing the client is not officially listed on a public register as a director or authorised signatory.

Q: What information should a PoA include?

A: A PoA must be carefully drafted to specify the attorney’s authority, which can be broad or limited to specific tasks. It serves as official proof to banks and other parties that the attorney has the legal right to act. The document must be validated and signed by the directors who are listed on the official company register.

4. Bank Account Details

Q: Why must the bank account be in my company’s legal name?

A: This is a security measure to ensure settlement funds are secure and to prevent misuse of third-party accounts.

Q: What documents are needed to verify the bank account?

A: A recent (within 90 days) bank statement or an official bank letter that shows your company's legal name, IBAN/account number, and the bank's name.

Q: Can you settle funds into an account from a different company?

A: No. We must settle all funds into a bank account that is under the legal name of the entity that was onboarded.

5. Special Cases & Enhanced Due Diligence (EDD)

Q: What is Enhanced Due Diligence (EDD)?

A: EDD is a more detailed review process for high-risk clients, such as those with PEPs, complex ownership structures, or from high-risk jurisdictions. This may include:

• Source of Funds (SoF): An explanation of how your company's operating funds are generated.
• Source of Wealth (SoW): Evidence (like tax returns or financial statements) that shows how an individual (especially a PEP) accumulated their overall wealth.

6. Support & Next Steps

Q: Who can I contact if I have questions during onboarding?

A: Your account manager is the best person to contact. They can direct any questions to the relevant team.

Q: How can I speed up the onboarding process?

A: The best way to expedite the process is to provide complete, clear, and up-to-date documents from the very beginning. Please ensure that all IDs are valid for at least six months, address proofs are dated within 90 days, and ownership information is well-documented and properly certified.

Q: What happens after onboarding is complete?

A: Once our Client Due Diligence team has completed their review, the case will be moved to the contract signature stage. After the contract has been signed, we will begin the configuration process and release your credentials so you can begin using our services.