Customer Due Diligence

Please provide the filled- in Questionnaire from Wolfsberg.

We request the Wolfsberg CBDDC from customers who are set up to perform client business in our system or the Financial Crime Compliance Questionnaire (FCCQ) from those for whom we have only set up accounts for proprietary positions.

Wolfsberg CBDDQ version 1.3 from 2020:
https://www.wolfsberg-principles.com/sites/default/files/wb/CBDDQ_V1.3_SC09_Final_Version_16APR2020.pdf

Wolfsberg FCCQ:
https://www.wolfsberg-principles.com/sites/default/files/wb/FCCQ_V1.1_SC04_Final_version_16APR2020.pdf

For more guidance how to fill in the questionnaire please go to:
https://www.wolfsberg-principles.com/

  ^{_{CBDDQ: Correspondent Banking Due Diligence Questionnaire
  FCCQ : Financial Crimes Compliance Questionnaire}}
 

In addition to the Wolfsberg Questionnaire we kindly ask you to fill in our CIT which is available in pdf format and consists of 6 parts:

• Part 1: Entity Information 
• Part 2: Ownership and Shareholder Structure
• Part 3: Executive Management (Board of Directors)
• Part 4: Sanctions Declaration 
• Part 5: MLRO and Sanctions Contact Details
• Part 6: Authorized Signatures

Please be aware that the document should be signed by authorized persons on the provided signature list.

As evidence that the Member firm is currently registered as an active legal person, please provide the most recent (six months or less) excerpt from the public register of companies or trade registry or the office of Secretary of State etc. of the relevant jurisdiction. It should be issued by the local authority which oversees company registrations or be downloadable from this authority’s website.

If an entry in the Register of Companies does not exist, corresponding evidence could be

• a Certificate of Incorporation, if it was issued less than six months ago, or
• provisions by law or in the articles of association applicable to the specific entity (e.g. for a central bank, the Central Bank Law of the respective jurisdiction).

Please provide this documentation as un editable electronic copy (in pdf format).

As evidence that the Member firm is licensed as a financial services provider and/or regulated or listed by the relevant authority or self-regulatory industry association according to the legal requirements of its jurisdiction, please provide an uneditable electronic copy (pdf) of the business license or evidence of supervision.

If your entity is established by a law or decree, please provide to us the proof of set up / establishment stating the respective legislative law, act or decree or an official document issued by the relevant governmental authority proving the set-up and supervision or a charter of public authorities (such as governmental decrees).

Please provide an uneditable electronic copy (pdf) of the most recent audited Annual Report with Financial Statements on your company. If an Annual Report is not published for your company, please provide the most recent annual financial statements.

Please provide the Memorandum and Articles of Incorporation / Articles of Association (or statutes or by-laws), Charta, or other document that governs your company and contains information on

• business purpose and list of activities the entity is authorized to exercise
• name of the regulator
• responsibilities of directors or management
• means by which the shareholders exercise control over the board of directors
• details whether the entity is allowed to issue bearer shares (shares owned by whoever holds the physical paper/stock certificate)

Please provide a visual representation of all significant shareholders, entities or governmental agencies owning or controlling directly or indirectly more than 10% of the company’s shares.

The ownership- and shareholder structure leads to the ultimate beneficial owner(s), i.e., a natural person who owns or controls directly or indirectly 25% or more of the entities shares, voting rights or exercises control by other means.

It is necessary to indicate the ownership or shareholding percentages with each connector in the chart.

In many companies, an ownership chart that contains this information is already included in the audited Annual Report. If this represents the current state at time of submission, it should be used here.

Please provide the board of directors (or executive management - CEO, CFO, COO). Persons with key functions that may effectively manage and/or exercise control the activities of the company. 

A copy of a valid passport / ID Card needs to be provided for all ultimate Beneficial Owners and other natural persons, where applicable. For the identification of Ultimate Beneficial Owners (natural persons) a copy of a valid Passport / ID Card is required which displays the following information:
Full name, place of birth, date of birth, citizenship, address of residence, nationality.

The list of authorized signatures must clearly state that the listed persons are authorized to represent the company. The correct name of the signatory and a sample of the corresponding signature must be shown next to it. The list must include the signature policy of the company which means that the information if every signatory can sign solely or jointly is required. Additionally, the list must have been issued and signed by persons who are authorized to give the representation authorization to individuals.