Last update:​​ 03.06.2021


All relevant definitions are outlined in FINANSIV’s Global Terms and Conditions (GTCs).


The following policy has been derived from the general principles, laws, regulations and directives for combating money laundering and based on international AML regulation procedures.

FINANSIV is taking security measures and has adopted adequate policies, practices and procedures that promote high ethical and professional standards and prevent the organization from being used, intentionally or unintentionally for criminal activity.

FINANSIV has placed adequate know your customer (KYC) programs.

Such essential elements start from the services, risk management and control and include:

  • Customer acceptance policy;

  • Customer identification;

  • On-going monitoring of high-risk accounts;

  • Risk management;

  • Categorization of clients on a risk basis;


FINANSIV is obliged not only to establish the identity of its customers, but also to monitor account activity to determine those transactions that do not conform with the normal or expected transactions for that customer or type of account.

KYC constitutes a core feature of services’ risk management and control procedures.
The intensity of KYC programs beyond these essential elements is tailored to the degree of risk.

  • ​​ Customer acceptance policy

FINANSIV maintains clear customer acceptance policies and procedures, including a description of the types of customer that are likely to pose a higher than average risk to an organization. Before accepting a potential client, KYC and due diligence procedures are followed, by examining factors such as but not limited to customers’ background, country of origin, public or high-profile position, linked accounts, business activities or other risk indicators.

Quite extensive due diligence is essential for an individual with a high net worth whose source of funds is unclear. New clients’ money is transferred through a reputable bank. Banks have their own anti-money laundering procedures.

A decision to enter into business relationships with higher risk (High 1) customers is taken exclusively at senior management level.

FINANSIV will not, under any circumstances accept very high-risk (High 2) customers.

  • Customer identification

Customer identification is an essential element of KYC standards. For the purposes of this paper, a customer includes: 

  • The person or entity that maintains an account with FINANSIV or those on whose behalf an account is maintained (i.e. Beneficial owners);

  • The beneficiaries of transactions conducted by professional intermediaries;

  • Any person or entity connected with a financial transaction who can pose a significant reputational or other risk to FINANSIV.

FINANSIV maintains a systematic procedure for identifying new customers and cannot enter into a service relationship until the identity of a new customer is satisfactorily verified.

Procedures document and enforce policies for identification of customers and those acting on their behalf. The best documents for verifying the identity of customers are those most difficult to obtain illicitly and to counterfeit. FINANSIV pays special attention in the case of non-resident customers and in no case is a short-circuit identity procedure is followed just because the new customer is unable to present enough documents and information to satisfy the KYC and due diligence procedures followed.

The customer identification process applies naturally at the outset of the relationship. To ensure that records remain up-to-date and relevant, FINANSIV undertakes regular reviews of existing records. An appropriate time to do so is when a transaction of significance takes place, when customer documentation 3standards change substantially, or when there is a material change in the way that the account is operated. However, if the compliance and anti-money laundering office and/or AML services company becomes aware at any time, through compliance and/or AML reviews, that it lacks sufficient information about an existing customer, takes immediate steps to ensure that all relevant information is obtained as quickly as possible.

FINANSIV can be exposed to reputational risk, and should therefore apply enhanced due diligence to such operations. Private accounts, which by nature involve a large measure of confidentiality, can be opened in the name of an individual, a commercial business, a trust, an intermediary or a personalized investment company. In each case reputational risk may arise if FINANSIV does not diligently follow established KYC procedures. All new clients and new accounts are approved by at least one person, the finance or the AML officer. In case of a new high-risk customer, the final decision is taken by the managing director.

Particular safeguards have been put in place internally to protect confidentiality of customers and their business, FINANSIV ensures that equivalent scrutiny and monitoring of these customers and their business is conducted, e.g. It is available to be reviewed by AML officer and auditors. 

FINANSIV maintains clear standards and policies, on what records must be kept on customer identification and individual transactions. Such practice is essential to permit FINANSIV to monitor its relationship with the customer, to understand the customer’s on-going business and, if necessary, to provide evidence in the event of disputes, legal action, or a financial investigation that could lead to criminal prosecution.

As the starting point and natural follow-up of the identification process, the least five years after an account is closed. FINANSIV also retains all financial transaction records for at least five years from the date when a firm’s relationship with the client was terminated or a transaction was completed.


  • General identification requirements

FINANSIV obtains all information necessary to establish to its full satisfaction the identity of each new customer and the purpose and intended nature of the business relationship. The extent and nature of the information depends on the type of applicant (personal, corporate, etc.) And the expected size of the account.

When an account has been opened, but problems of verification arise in the service relationship, which cannot be resolved, FINANSIV can close the account and return the

Money to the source from which they were received. While the transfer of an opening balance from an account in the customer’s name in another organization subject to the same KYC standard, it will be considered, however we will do our own KYC procedures because we should nevertheless consider the possibility that the previous account manager may have asked for the account to be removed because of a concern about dubious activities.

Naturally, customers have the right to move their business from one organization to another. However, if FINANSIV has any reason to believe that an applicant is being refused service facilities by another organization, applies enhanced due diligence procedures to the customer.

FINANSIV will never agree to open an account or conduct ongoing business with a customer who insists on anonymity or who gives a fictitious name. Nor should confidential numbered accounts function as anonymous accounts but they should be subject to exactly the same KYC procedures as all other customer accounts, even if the test is carried out by selected staff. Whereas a numbered account can offer additional protection for the identity of the account-holder, the identity must be known to enough staff to operate proper due diligence.

  • Specific customer due diligence and identity procedures

Customer identification must be carried out as soon as reasonably practicable after first contact is made. Except its obligation to exercise due diligence and customer identification, FINANSIV must confirm that the identity info which holds for its 5customers must remain fully informed and updated with all necessary identification and information throughout their business relationship. FINANSIV review and monitor on a regular basis the validity and adequacy of customer identification information in its possession.

Notwithstanding the above and taking into account the degree of risk, if realized at any time during the business relationship that FINANSIV lacks sufficient or reliable evidence (data) and information on the identity and financial profile of an existing customer, FINANSIV immediately takes all necessary actions using the identification procedures and measures to provide due diligence, in order to collect the missing data and information as quickly as possible and in order to determine the identity and create a comprehensive financial profile of the customer. 

Furthermore, FINANSIV monitors the adequacy of the information held and identity and economic portrait of its customers when and where one of the following events occurrences:

  • Conduct of a significant transaction that appears to be unusual and/or significant than the usual type of trade and economic profile of the client;

  • A significant change in the situation and legal status of the client as but not limited to:

  • Change of directors/secretary;

  • Change of registered shareholders and/or actual beneficiaries;

  • Change of registered office;

  • Change of trustees;

  • Change of corporate name and/or trade name;

  • Change of main trading partners and/or significant new business;

  • A significant change on the way and operating rules of the client’s account, such as but not limited to;

  • Change of persons authorized to handle its account;

  • Request for opening a new account in order to provide new investment services and/or financial instruments

In case of customer transaction via internet, phone, fax or other electronic means where the customer is not present to verify the authenticity of his/her signature, or that is the person who actually owns the account, or is authorized to handle the account, FINANSIV established reliable methods, procedures and practices to control access to electronic means to ensure that deals with the actual owner or authorized signatory of the account.

Where the client refuses, or fails to provide FINANSIV with the required documents and information for identification and creation of economic portrait, before entering into the business relationship, or during the execution of an individual transaction without adequate justification FINANSIV will not proceed in a contractual relationship or will not execute the transaction and may also report it to AML officer. This can lead to a suspicion that the client is engaged in money laundering and terrorist financing.

If during the business relationship the client refuses or fails to submit all required documents and information, within reasonable time, FINANSIV has the right to terminate the business relationship and close the accounts of the client. The compliance department also examines weather to report the case to AML officer.

  • ​​ personal customers details required:

  • E-mail;

  • Phone number (will be verified by phone call by employee or via SMS system);

  • True name and/or names used;

  • Current permanent address, including postal code;

  • Date of birth.

  • Names should be verified by reference obtained from a reputable source which bears a photograph, such as but not limited to:

  • Current valid full passport;

  • National id card.

  • In addition to the clients’ name verification, the current permanent address should be verified by (originals) by obtaining any one of the following:

  • Copy of a recent utility bill;

  • Local tax authority bill;

  • Bank statement;

  • Checking a telephone directory;

  • Credit card monthly statement

In an addition to the above an introduction from a respected customer personally known to the manager of FINANSIV or from a trusted member of staff, can assist the verification procedure. Details of the introduction should be recorded on the customer’s file.

  • Accounts for corporate customers:

  • Company searches, and other commercial enquiries, to ensure that the applicant has not been or in the process of being dissolved, struck off, wound up or terminated;

  • Changes to company structure occur or ownership occur subsequently, further checks should be made;

  • Identity verification should aim to identify:

  • The company;

  • The directors;

  • All persons duly authorized to operate the account;

  • In case of private companies, the major beneficial shareholders;

  • The company’s business profile in terms of nature and scale of activities


  • The following documents are required:

  • The original or certified copy of the certificate of incorporation;

  • Memorandum and articles of association;

  • Resolution of the board of directors to open an account with FINANSIV;

  • Where appropriate a search of the file at the companies’ registry;

  • Identity of individuals who are connected with the company



FINANSIV must be satisfied that is dealing with a real person, and for this purpose, obtains sufficient identification documents to prove that is the person who claims to be.

FINANSIV must verify the identity of beneficial owners of accounts. For legal persons, receives such data and information to understand the ownership and control structure of the customer. Regardless of the customer’s type (e.g. Natural or legal person, partnership or sole trader), we take adequate data and information on the customer’s business activities and the expected pattern and level of transactions.

 the identity of all customers is verified on the basis of reliable data and information given or received from independent and reliable sources, i.e. Those data and information that is difficult to be falsified or to be obtained in an illegal way.

 The home address and work are considered a key element of the identity of a person

 In no case is accepted as evidence the same info (data), for identifying a customer’s identity and residence proof.

All data and information must be collected before entering into the business relationship in order to create the financial portrait of the client and, as a minimum, includes the following:

  • The purpose and justification (reason) for the conclusion of the business relationship;

  • The anticipated turnover of the account, the nature of transactions, the expected source of money to be credited to the account and the expected destination of outgoing payments;

  • The size of assets and annual income, a clear description of the major business / professional activities / work.

The data and information that makes the financial portrait of the client - legal person includes:

  • Company name;

  • Country of incorporation;

  • Headquarters address;

  • Names and identity of beneficial owners;

  • Directors, authorized signatories;

  • Financial data;

  • Information for the group that may be owned by the company (country of incorporation of mother company, subsidiaries and associated companies, the principal activities, financial results).


All above data and information will be recorded on a separate form which is filed in the client’s file along with all other documents, and internal memos from the minutes of the meetings with the client. This form is updated in regular intervals or whenever new information on any changes or additions occurs to the elements that makes the financial profile of the customer.



FINANSIV applies increased due diligence measures and customer identification procedures in the following cases:

  • Where the customer has not been physically present for identification purposes;

  • In respect of cross-frontier correspondent banking relationships with credit institutions-customers from third countries;

  • In respect of transactions or business relationships with politically exposed persons residing in a country within the European economic area or a third country.

Enhanced customer due diligence measures are taken in all other instances which due to their nature entail a higher risk of money laundering or terrorist financing.

FINANSIV​​ can inquire and obtain additional documents and information at any time and for any reason in regards to the prevention of money laundering, terrorist financing and other forms of financial crime.

If any of the required document do not exist in the form required by FINANSIV, we may accept a similar document, provided that it serves the needs of due diligence.


FINANSIV may rely on third parties for applying the requirements in respect of customer’s identification procedures and customer due diligence measures provided that all data and information held by the third person for customer identification, which are certified copies of the originals is provided to FINANSIV.


We will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business. (red flags are identified in section​​ 6.2​​ below.)

The AML officer or their designee will be responsible for this monitoring, will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the appropriate authorities. The AML officer or their designee will conduct an appropriate investigation and review relevant information from internal or third-party sources before the authorities are notified.

  • Emergency notification to law enforcement by telephone

In situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, we will immediately call an appropriate law enforcement authority.

  • Red flags that signal possible money laundering or terrorist financing include, but are not limited to:

  • Customers​​ – Insufficient or Suspicious Information

  • Provides unusual or suspicious identification documents that cannot be readily verified.

  • Reluctant to provide complete information about nature and purpose of business, prior banking relationships, anticipated account activity, officers and directors or business location.

  • Refuses to identify a legitimate source for funds or information is false, misleading or substantially incorrect.

  • Background is questionable or differs from expectations based on business activities.

  • Customer with no discernible reason for using FINANSIV’s service.

  • Efforts to Avoid Reporting and Recordkeeping

  • Reluctant to provide information needed to file reports or fails to proceed with transaction.

  • Tries to persuade an employee not to file required reports or not to maintain required records.

  • “Structures” deposits, withdrawals or purchase of monetary instruments below a certain amount to avoid reporting or recordkeeping requirements.

  • Unusual concern with FINANSIV’s compliance with government reporting requirements and FINANSIV’s AML/CFT policies.

  • Certain Funds Transfer Activities

  • Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent business reason.

  • Many small, incoming wire transfers or deposits made using checks and money orders. Almost immediately withdrawn or wired out in manner inconsistent with customer’s business or history. May indicate a Ponzi scheme.

  • Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent business purpose. Activity Inconsistent with business.

  • Transactions patterns show a sudden change inconsistent with normal activities.

  • Unusual transfers of funds or journal entries among accounts without any apparent business purpose.

  • Maintains multiple accounts, or maintains accounts in the names of family members or corporate entities with no apparent business or other purpose.

  • Appears to be acting as an agent for an undisclosed principal, but is reluctant to provide information.

  • Other Suspicious Customer Activity

  • Unexplained high level of account activity with very low levels of securities transactions.

  • Funds deposits for purchase of a long-term investment followed shortly by a request to liquidate the position and transfer the proceeds out of the account.

  • Law enforcement requests.

  • Responding to Red Flags and Suspicious Activity

When an employee of FINANSIV detects any red flag, or other activity that may be suspicious, they will notify the AML officer. Under the direction of the AML officer, FINANSIV will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and/or informing the authorities.

  • Suspicious Transactions Reporting

  • Filing a report with the State Agency for National Security

  • We will file a report with the authorities for any transactions (including deposits and transfers) conducted or attempted by, at or through FINANSIV involving EUR 5 000 or more of funds (either individually or in the aggregate) where we know, suspect or have reason to suspect:

  • Тhe transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade law or regulation or to avoid any transaction reporting requirement under law or regulation;

  • Тhe transaction is designed, whether through structuring or otherwise, to evade any requirements of the regulations;

  • Тhe transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction;

  • Тhe transaction involves the use of FINANSIV to facilitate criminal activity.

We will also file a report and notify the appropriate law enforcement authority in situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes.

We may file a voluntary report for any suspicious transaction that we believe is relevant to the possible violation of any law or regulation but that is not required to be reported by us. It is our policy that all suspicious activities will be reported regularly to the Board of Directors and appropriate senior management.

  • Currency Transaction Reports

FINANSIV only accepts currency transactions through financial institutions and internationally recognized and licensed payment platforms.

Any transfers above EUR 5 000 may be reported to the authorities.


We will keep logs of our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain logs that describe the methods and the results of any measures we took to verify the identity of a customer. We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained.

Relevant evidential material and details of all business relations and transactions, including documents for recording transactions in the accounting books and relevant documents of correspondence with the customers and other persons with whom they keep a business relation will also be kept.

FINANSIV is required to keep records for a period of at least 5 years by the law.

The 5-year period is calculated following the carrying out of the transactions or the end of the business relationship.

All documents and information are available rapidly and without delay to the authorities for the purpose of discharging the duties imposed on them by the law.


Effective KYC procedures embrace routines for proper management oversight, systems and controls, segregation of duties, training and other related policies.

The board of directors of FINANSIV is fully committed to an effective KYC program and procedures and ensures their effectiveness. Explicit responsibility is allocated within the organization for ensuring that FINANSIV’s policies and procedures are managed effectively and are in accordance with local supervisory practice. The channels for reporting suspicious transactions are clearly specified and communicated to all personnel.

FINANSIV maintains an ongoing employee-training program so that the staff is adequately trained in KYC procedures. The timing and content of training for various sectors of staff is adapted by FINANSIV for its own needs. Training requirements should have a different focus for new staff, front-line staff, compliance staff or staff dealing with new customers. New staff should be educated in the importance of KYC policies and the basic requirements at the organization.

Staff members who deal directly with the customers are trained to verify the identity of new customers, to exercise due diligence in handling accounts of existing customers on an ongoing basis and to detect patterns of suspicious activity. Regular refresher training is provided to ensure that employees are reminded of their responsibilities and are kept informed of new developments. It is crucial that all relevant staff fully understand the need for and implement KYC policies consistently. A culture within services that promotes such understanding is the key to a successful implementation.

    FINANSIV has determined the following risk levels:

  • “Normal”
    The risk level is normal, there are no high-risk characteristics present.

  • “High 1”

  • Resident / Citizen of high-risk country such as but not limited to: Bahrain, Yemen, Jordan, Kuwait, Lebanon, Libya, Malaysia, Mali, Mauritania, Nigeria, Oman, Somalia, Serbia, Sri Lanka, Sudan, Tunisia, Turkey, Trinidad fi Tobago.

  • Resident / Citizen of a low tax or tax-free country such as but not limited to: United Arab Emirates, Oman, Bahrain, Qatar, Saudi Arabia, Kuwait, Bermuda, Cayman Islands, The Bahamas, Brunei, Vanuatu, Anguilla, Belize, Costa Rica, Guatemala, Panamá, Nicaragua.

  • User is a politically exposed person (PEP) such as but not limited to the: prominent public functions :head of state, head of government, minister and deputy or assistant minister; a member of parliament or of a similar legislative body, a member of a governing body of a political party, a member of a supreme court, a member of a court of auditors or of the board of a central bank; an ambassador, a chargé d’affaires and a high-ranking officer in the armed forces; a member of an administrative, management or supervisory body of a state-owned enterprise; a director, deputy director and member of the board or equivalent function of an international organization, except middle-ranking or more junior officials.

  • The legal person’s area of activity is associated with enhanced money-laundering risk;

  • The legal person is situated in a country, which is listed in the list of high-risk or low-tax countries;

  • The legal persons activities and liability are insufficiently regulated by law, and the legality of financing of which is not easy to screen;

  • The representative or the Beneficial Owner / Shareholder of a legal person is a local PEP or their family member is a PEP.

  • A legal person registered outside the European Economic Area, whose field of business is associated with a high risk of Money Laundering, or registered in a low tax rate country.

  • “High 2”

  • Country of residence / nationality is a country with prohibition/restriction on cryptocurrencies such as but not limited to: Afghanistan, Algeria, American Samoa, Bangladesh, Bolivia, China, Democratic Republic Of Congo, Democratic People’s Republic Of Korea (Dprk), Ecuador, Egypt, Ethiopia, FYR Macedonia, India, Iran, Iraq, Kyrgyzstan, Pakistan, Palestine, Qatar, Saudi Arabia, Syria, Morocco, Nepal, United States Of America, Vanuatu, Vietnam, Zambia.

  • Suspicious facts such as but not limited to the: discrepancies in provided id documents, fictitious person, stolen identity, counterfeited id document, post box home address, pervious financial crime record, terrorist record, wanted person, no contact phone number, not valid documents, discrepancies in provided documents for the legal person, etc.

  • The legal person is situated in a country, with prohibition/restriction on cryptocurrencies.

  • User is suspected to be or to have been linked with a financial offence or other suspicious activities;

  • There is information that legal person is suspected to be or to have been linked with a financial offence or other suspicious activities.


  • Natural persons:

The following documentation should always be verified by FINANSIV:

  • True name and / or names used, based on the official identity card or passport;

  • Document issued by an independent and reliable source and which bears a photograph of the customer;

  • Full permanent address, including the postcode, presentation of a recent (up to 6 months) telephone bill, electricity, municipal taxes, or bank account statement, or similar, with the above, documents;

  • Mobile phone number, landline or fax;

  • E-mail address;

  • Date and place of birth;

  • Nationality;

  • Details of profession and other occupations, including the name of the employer/ business organization

  • In addition to the above, where the client was introduced by a trusted member of the staff of FINANSIV, or by other reliable existing client or a third person personally known, member of the board of directors, details of these recommendations must be produced and kept in the client’s file.

  • Joint accounts

Joint accounts are strictly prohibited.

  • Accounts of unions, societies, clubs, provident funds and charitable institutions

The following documentation should always be verified by FINANSIV:

  • Memorandum and articles of association;

  • Registration documents;

  • Certificate of registration;

  • List of the members of the board of directors/ management committee;

  • Resolution of the board of directors to enter into transactions on the forex market and conferring authority to those who will act for the customer;

  • The identity of all authorized persons; 

  • Accounts of unincorporated businesses, partnerships and other persons with no legal substance

 the following documentation should always be verified by FINANSIV:

  • Identity of the directors/partners;

  • Identity of the beneficiaries;

  • Identity of authorized persons;

  • In the case of partnerships, the original or a certified true copy of the partnership's registration certificate;

  • Business address;

  • Nature and size of its activities

  • The financial portrait of the legal person which includes:

  • Identity info;

  • Identity of beneficiaries;

  • In case of legal persons (ownership and control structure, of the customer);

  • Information regarding the business activities and the expected pattern and level of transactions;

  • Residence and business address;

  • The purpose and reason for the establishment of a business relationship;

  • Anticipated account turnover, the nature of the transactions, the expected origin of incoming funds to be credited to the account and the expected destination of outgoing transfers/payments;

  • The customer’s size of wealth and annual income, and a clear description of the main business / professional activities / operation;

  • Company’s name, country of incorporation, head offices address, names and identity of beneficial owners, directors, authorized signatories, financial information, ownership structure of the group that the company may be a part of (country of incorporation of the parent company, subsidiaries and associate companies, the main activities, financial information);

  • Where a formal partnership agreement exist, must be provided and also a mandate from the partnership authorizing the opening of the account and confirming authority to a specific person who will be responsible for its operation.

  • Accounts for legal persons

The following documentation should always be verified by FINANSIV:

  • Registration number​​ – certificate of registration;

  • Registered name and trade name used;

  • Full corporate registered address and head officers;

  • Phone number, fax and email address;

  • Members of the board of directors;

  • Persons authorized to operate the account and to act on behalf of the legal;

  • Real beneficiaries of private and public companies that are not listed in regulated market of a European economic area country or a third country with equivalent disclosure and transparency requirements.

  • Registered shareholders that act as nominees of the actual beneficiaries;

  • The financial portrait of the legal person which includes;

  • Identity info;

  • Identity of beneficiaries;

  • In case of legal persons (ownership and control structure, of the customer);

  • Information regarding the business activities and the expected pattern and level of transactions;

  • Residence and business address;

  • The purpose and reason for the establishment of a business relationship;

  • Anticipated account turnover, the nature of the transactions, the expected origin of incoming funds to be credited to the account and the expected destination of outgoing transfers/payments;

  • The customer’s size of wealth and annual income, and a clear description of the main business / professional activities / operation;

  • Company’s name, country of incorporation, head offices address, names and identity of beneficial owners, directors, authorized signatories, financial information, ownership structure of the group that the company may be a part of (country of incorporation of the parent company, subsidiaries and associate companies, the main activities, financial information);

  • Certificate of incorporation;

  • Good standing certificate;

  • Certificate of registered address16;

  • Certificate of directors and secretary;

  • Memorandum and articles of association;

  • Certificate of registered shareholders in the case of private and public companies that are not listed in regulated market of a European economic area country or a third country with equivalent disclosure and transparency requirements;

  • Resolution of the board of directors for opening the account and granting authority to those who will operate it.

  • In case of nominee shareholders of the actual beneficiaries, a copy of the trust deed signed between the nominee shareholder and the beneficial owner, by virtue of which the registration of the shares on the name of the nominee shareholder on behalf for the real beneficiary has been agreed;

  • Documents and data to establish, the identity of persons authorized by the legal person to operate the account, as well as the registered shareholders and beneficial owners of the legal person;

  • Where necessary, a copy of the latest audited financial statements (if available) and / or copies of its latest management accounts.

 it is noted that at any times during the business relationship, the company can obtain additional documents and information if required.

  • Accounts for legal persons (companies or legal entities):

  • All documents and information as stated in section​​ 9.5​​ above must be provided.

  • The company can conduct research and receive information from the companies registry or equivalent authority in the country of incorporation (legal entity) abroad and / or request information from other sources in order to ensure that the company (legal person) is not nor is in the process of being dissolved or liquidated or struck off the registry and that it continues to be registered as an operating company.

  • Shareholder​​ – another entity

In case of client - legal person applying for a FINANSIV account and whose sole or direct shareholder is another legal person, the following must be provided:

  • All documents as provided in section​​ 9.5;

  • Ownership structure;

  • Identity of the individual beneficial owners or/and control the other legal person;

  • Identity of persons who have the ultimate control over the legal person’s business and assets as describes in part a

  • In the cases that the ultimate control is in the hands of the persons who have the power to manage the funds, accounts or investments of the legal person, without the need for further authorization and who would be in a position to override the internal procedures, we need the identity of persons exercising effective control, as defined in section​​ 9.1, even if they have no direct or indirect interest or an interest of less than 10% of ordinary share capital or voting rights of the legal person.

  • Shareholder - trust

If the beneficial owner of an entity is a trust then the following documents are required:

  • Name;

  • Date of establishment;

  • Identity of the trustee (as per section​​ 9.1);

  • Identity of the trustee (as per section​​ 9.1);

  • Identity of the beneficial owners (as per section​​ 9.1);

  • The nature and purpose of the establishment and activities (memorandum and articles of association);

  • Origin of funds, extracts from the trust agreement and other relevant information from the trustees


  • Investment funds, mutual funds and firms providing financial or investment services:

  • A license or authorization from a competent supervisory/regulatory authority of the country of incorporation and operation to provide the said services.

  • Evidence that are subject to the supervision for the prevention of money laundering and terrorist financing purposes.

  • In case the person is incorporated and/or operating in a third country the following must be obtained:

  • All documents as stated above in section​​ 9.5;

  • Copy of the license or authorization granted from a competent supervisory/regulatory authority of its country of incorporation and operation;

  • Sufficient data and information to fully understand the control structure and management of the business activities and the nature of the services and activities provided by the customer;

  • In the case of investment funds and mutual funds the financial organization must provide the following:

  • Identity of the beneficial owners;

  • Information regarding their objectives and control structure, including documentation and information for the verification of investment managers, investment advisors, administrators and custodians



 the following information is required:

  • Verify the identity of the nominees or the agent of the third person;

  • Verify the identity of any third person on whose behalf the nominee is acting;

  • Copy of the authorization agreement that has been concluded between the interested parties;



  • Definition

“shell bank” – a bank that has no physical presence in the country in which it is incorporated and licensed, and which is unaffiliated with a regulated financial group that is subject to effective overall supervision. The physical presence constitutes being located within a country performing a management function with meaningful mind and the mere existence of a local agent or non-managerial staff does not constitute a physical presence.

  • Policy:

  • FINANSIV shall not enter into any business relationship with a shell bank. 

  • FINANSIV shall not conduct transactions with, on behalf and from of shell banks through any of its accounts or products. 



FINANSIV has reviewed all areas of its business to identify potential money laundering and/or financing of terrorism risks that may not be covered in the procedures described above. The major additional areas of risk include future changes to regulations and hacking attempts on FINANSIV’s servers. Additional procedures to address these major risks are maintaining constant contact with the State Agency for National Security and performing daily security checks on FINANSIV’s server security procedures, performed by a dedicated server security specialist.


Senior management has approved this AML/CFT policy in writing as reasonably designed to achieve and monitor our firm’s ongoing compliance with the current European regulation.