KYC / AML Procedures for investors

On Boarding Procedure Investors

KYC/AML Investor Procedures

KYC (Know Your Customer) guidelines in financial services require professionals to make an effort to verify the identity, eligibility and risks associated with maintaining a business relationship. In that context, procedures have been made mandatory.

The procedures fit within the broader scope of our company's anti-money laundering policy.

KYC processes are also used by companies of all sizes to ensure that their proposed customers, agents, consultants or distributors are anti-bribery compliant and are actually who they claim to be.

Identification (KYC/AML procedure)

On this page:

• Identification procedure for new investors

• Procedure for natural persons

• Procedure for organizations

• CRS forms

• Requirements for identification documents

• For your first purchase order

Identification procedure for new investors

We are legally obliged to follow a certain identification procedure for new investors. Part of this is that you must indicate whether you are tax resident in another country. We also need to check whether you are not on certain sanctions lists. These are lists containing persons and organizations to which financial services may not be provided, eg because of the undertaking of terrorist activities.

This procedure only applies to new investors. If you want to buy more later, this procedure is no longer important. However, the checks are performed periodically by us. We may also ask you to re-enter your tax status.

Procedure for natural persons

The following applies to natural persons:

• You send in your registration form, together with a copy of proof of identity and a completed CRS form.
• If the questions regarding tax status are already included on the registration form, a separate CRS form is no longer necessary. This differs per product or fund.
• If this is a joint investment, please send copies of each investor's ID and CRS forms listed on the application form.
• You transfer your first deposit from an account in your own name. This is called 'derivative identification'.
• The account may also be an and/or account. As long as it is in the name of one of the investors. In that case, we will ask the other investor for an identification deposit.
• We will check this ascription upon receipt of your deposit. With and/or invoices it happens that not the entire ascription is visible, so that your name cannot be read. In that case, we will ask you to send a copy of your bank statement.
• In special situations you can also have your investment transferred directly from an account that is not in your name, for example directly from the civil-law notary or from an insurer. We will then ask the relevant organization for confirmation that the transfer actually originated from you. This is called 'derivative identification'.
• However, this must be a bank account with a 'trusted' bank or. from a 'familiar' country. The bank must have checked the origin of the funds (anti-money laundering/anti-terrorism legislation). In most cases, however, this will be met.
• Unfortunately, it happens that the organization in question does not send us a confirmation (in time). In that case, we may ask you to make an additional identification deposit from your own account that is in your name. Here you can suffice with a minimum amount, eg € 0.01.

Procedure for organizations

The following applies to non-natural persons:

• You send in your registration form, together with recent extracts from the Trade Register and the UBO register of the Chamber of Commerce of the organization, a completed CRS form for the organization, and a copy of proof of identity of the persons you want to authorize to later use any to issue change orders. Read the requirements for the identification documents carefully.
• If more than one person is authorized within your organization, it is also sufficient to pass on one person. You can always change these authorized persons. Only then will we need a copy of proof of identity from those persons at a later date.
• The authorized persons are often not listed on the Chamber of Commerce extract, but are authorized via a parent entity. In that case, you also send in a recent extract from the parent entity (eg the holding BV). If there are multiple tiers, send extracts from all overlying tiers until the authorized individuals are listed. Only then can we determine that the persons concerned are authorized to carry out transactions on behalf of your organization.
• In addition to the authorized persons, we are also legally obliged to identify the ultimate beneficial owner(s) themselves, despite the statement of the UBO register. The ultimate beneficial owners are usually the owners of a company. Although there can also be several layers of ownership, in the end there is always a natural person the owner. You should also send in a copy of proof of identity for these persons, together with the Chamber of Commerce extracts of any intermediate entities.
• If the ultimate beneficial owner is equal to the authorized person, and the ownership structure is equal to the governance structure, then this obligation has of course already been met.
• If the ultimate beneficial owners (owners, shareholders) are not listed in the Chamber of Commerce extract, we need additional documents to determine the ultimate beneficial owners. Please also send in an up-to-date copy of the shareholders' register. If this register is not yet available or is no longer available, you can also submit the deed of incorporation or articles of association of the entity.
• You transfer the deposit. This must come from an account in the name of the organization.
• This must also be a bank account with a 'trusted' bank or. from a 'familiar' country. The bank must have checked the origin of the funds (anti-money laundering/anti-terrorism legislation). In most cases, however, this will be met.

Requirements for identification documents

Identification

The following are valid proof of identity:

• Passport
• ID card
• Residence document under the Aliens Act
• Drivers license

Please note the following:

• The signature must be clearly legible in the copy or scan. Based on this, we check any change orders, for example the sale of your investment. To prevent misuse, your signature must be clearly legible.
• Your Citizen Service Number (BSN) must also be clearly legible, so that we can check the citizen service number you have provided. With a driver's license you must therefore also copy or scan the back.
• If the citizen service number is not stated on your proof of identity, we would like to receive another document stating your citizen service number.

Excerpt Chamber of Commerce

• Not older than 3 months.
• An electronic extract is also good, provided you have it sent to us directly by the Chamber of Commerce, to the e-mail address info@ebcplus.nl

CRS forms

Under the Common Reporting Standards laws and regulations, we are required to determine your tax status. In short, this means that you must fill in a form on which you must indicate in which country you are tax resident.

Various forms are available for individuals and organizations:

• CRS form private individuals (NL)
• CRS form organizations (NL)
• CRS self-certification form individuals (EN)
• CRS self-certification form entities (EN)

For your first purchase order

The main rule here is that identification and other checks are carried out before entering into the business relationship.

(Source: Money Laundering and Terrorist Financing Prevention Act). Your first purchase transaction cannot therefore be processed earlier after the identification procedure has been completed.