Below, we explain the basis upon which we carry out our mandatory compliance checks. If we are carrying these out for a third party (say, a client of ours), we apply the same standard as we do for our own clients.

Purpose

These requirements apply to onboarding and approval of a corporate client, and to any subsequent refresh where we identify a change in ownership, control, or risk profile.

Definitions

Corporate Clients

We may request additional information where required to satisfy our legal and regulatory obligations, proportionate to risk

Corporate Structures

Where the Entity for Review has any corporate beneficial owner, we require a group structure chart showing the ownership and control chain up to the ultimate beneficial owners and controllers.

Group Structure Chart

The group structure chart must be certified by a director, company secretary, lawyer, or accountant, with the following endorsement:

I certify that this is a true and accurate representation of the ownership and control of [Entity for Review] and the other entities shown, as at [date].

To the best of my knowledge and belief, other than those listed on this chart, there are no individuals or entities who ultimately own or control, whether through direct or indirect ownership or control, including through bearer share holdings, nominee arrangements, or other means:

(a) 25% or more of the shares or voting rights in any relevant entity. (b) control over the management of any relevant entity. (c) significant influence or control over any relevant entity.

Date of Chart

The group structure chart should be dated within the last 3 months.

We may accept an older chart where there is a clear basis to conclude there has been no change.

We may require a more recent chart, or externally certified evidence, where we consider that risk or complexity would justify this.

Corporate Documents

For the Entity for Review and each corporate beneficial owner, and any other corporate entity able to exercise control, we require:

• Certificate of incorporation or equivalent formation document.
• Constitutional documents, including articles of association or equivalent.
• Register of directors or equivalent, and current director list.
• Register of shareholders or equivalent, or alternative evidence of shareholding where a formal register is not available.
• Confirmation of all beneficial owners and controllers, including those identified as PSCs where applicable.
• Evidence of principal place of business and trading address, where different from registered office.
• Board resolution, written resolution, or equivalent authorising account opening and appointing signatories.

Overseas Entities

We require local equivalents to the above, plus any public registry extracts available in the jurisdiction. Where documents are not in English, we require a certified translation from a lawyer, notary, chartered accountant, or accredited translator.

We may also require:

• Certificate of good standing or equivalent (where available).
• Public registry extract (or equivalent official extract) evidencing directors, shareholders, and any beneficial ownership filings.

Certification and Legalisation - Risk-Based

For UK companies, we verify the information provided against the publicly-available information available at Companies House.

Where appropriate to the jurisdiction and risk profile, we may require notarisation and or apostille, and we may request direct verification from a regulated professional.

Public Authorities / UK Government Departments

We may request additional information where required to satisfy our legal and regulatory obligations, proportionate to risk

Our requirements for public authorities and UK Government departments are as follows. We do not request shareholder, beneficial owner, or PSC information for UK public authorities, as these concepts generally do not apply. We focus instead on mandate, governance, and authority to act.

Identity and legal status of the body

• The authority’s full legal name and registered address.
• Evidence of legal status, being one of:
  • Link to the establishing legislation or statutory instrument, or
  • Official register entry where applicable (for example, Charity Commission, Companies House, NHS body register), or
  • A link to the authority’s official government page confirming its status and name.
• Where the authority is incorporated. Certificate of incorporation and constitutional document.

Governance and Authority to Instruct

• Scheme of delegation, standing orders, or financial regulations extract showing who can approve the arrangement and instruct payments.
• Evidence of approval to proceed. Board or committee minutes, written resolution, or formal decision record, referencing the relevant delegated authority.
• A list of authorised signatories and approvers, including job title, department, and approval limits.

Bank Account & Payment Controls

• Bank account details for the sending account, confirmed on headed paper or by an official bank document.
• A recent bank statement for the sending account showing the authority name and account number.
• Confirmation of whether payments will be made by bank transfer only, and whether dual authorisation applies internally.

Source of Funds / Public Money Evidence

Provide one of the following to evidence the lawful basis and purpose of funds being paid:

• Budget allocation and cost centre reference, or
• Grant award letter or funding agreement, or
• Contract or call off, plus purchase order, plus invoice or payment certificate where applicable.

Individual Verification

All relevant individuals must complete identity verification via Credas.

Credas will request:

• Proof of identity. Passport, photocard driving licence, or government issued national identity card.
• Proof of address. Bank statement or utility bill dated within the last 3 months, or another acceptable document under our policy.

Source of Funds / Source of Wealth

We may request additional information where required to satisfy our legal and regulatory obligations, proportionate to risk

Who must provide this

The sending party. This is whichever entity or individual will send funds into the account, or pay bills from the account, or both.

We do not accept third party funding without prior approval and completion of KYC and Source of Funds and Source of Wealth on the third party.

Source of Funds - Minimum

A bank statement in the sending party’s name for the account from which funds will be sent, showing the account number and name, and sufficient transaction history to support the intended funding pattern (typically three months or more).

Sources of Wealth

We require a clear explanation of how the sending party acquired the funds being used, supported by evidence appropriate to the scenario. Where bank statements are requested, they should typically cover the last three months or sufficient detail to evidence the route of funds.

A non-exhaustive list of examples we may ask for:

Salary, employment income

• Recent payslips, plus employment contract or employer letter.
• Bank statements showing salary credits.

Dividends

• Dividend vouchers or board resolutions.
• Company accounts and, where relevant, Companies House filings.
• Bank statements showing dividend receipts.

Business profits, self employment, partnership drawings

• Latest filed accounts and or management accounts.
• Tax return or accountant letter.
• Bank statements showing relevant trading receipts and transfers.

Sale of a business

• Sale and purchase agreement and completion statement.
• Evidence of receipt of proceeds into the sending account.

Sale of property or other real asset

• Completion statement and sale contract.
• Land Registry evidence where relevant.
• Bank statements showing receipt.

Inheritance

• Grant of probate or equivalent.
• Executor statement or estate accounts.
• Bank statements showing distribution.

Gift

• Gift letter or deed of gift.
• Donor identity verification where required by risk.
• Donor Source of Wealth evidence, proportionate to the gift size and risk.
• Bank statements showing transfer from donor to recipient.

Loan

• Signed loan agreement and terms.
• Evidence of lender identity and lender Source of Wealth, proportionate to risk.
• Bank statements showing drawdown.

Investment proceeds, cryptoasset realisation, portfolio liquidation

• Broker or platform statements showing holdings and disposal.
• Transaction confirmations.
• Bank statements showing proceeds.
• For cryptoassets, wallet evidence and exchange statements, with narrative of acquisition and realisation.

Litigation settlement, insurance payout, compensation

• Settlement agreement or court order where applicable.
• Payer confirmation letter and remittance advice.
• Bank statements showing receipt.

Trust distributions

• Trust deed extract identifying settlor and beneficiaries, and distribution power, plus trustee identification.
• Trustee resolution or distribution letter.
• Bank statements showing distribution.

Company group funding, intercompany transfers

• Group chart and corporate approvals.
• Intercompany loan agreement or capital contribution documentation.
• Bank statements from originating entity.

General Rule

The evidence should allow us to understand the origin of the wealth, the route of the funds, and the reason the funds are available now, with a level of detail proportionate to risk.