Document Requirements Overview
Beneficial Owner (UBO): Any individual who owns 25% or more of the business.
Control Person: Individual(s) with significant management authority or control over the business (directors, officers, authorized signatories).
You must collect documents across three categories: Core Business Documents, Ownership & Control Documents, and additional requirements for Money Movement Businesses.
A. Core Business Documents
All businesses must provide the following documents:
1. Certificate of Incorporation (Required)
| Document Type | What to Collect |
|---|
| Certificate of Incorporation | Official document proving the company is legally registered |
| Articles of Incorporation | Founding document (may be called Formation Documents) |
2. Business Registration Number (Required)
| Document Type | What to Collect |
|---|
| Tax Identification Number | EIN or ITIN for US businesses, Tax ID or VAT number for international entities |
3. Corporate Structure Documents (Required)
| Document Type | What to Collect |
|---|
| Shareholder Registry | Document showing who owns the company and their ownership percentages (also called cap table) |
| Corporate Structure | Organizational chart or document showing the company’s ownership structure |
| Director’s Registry | List of all directors and officers of the company |
4. Proof of Physical Address (Required)
| Document Type | What to Collect |
|---|
| Proof of Physical Address | Document proving where the business operates (utility bill, lease agreement, or bank statement). Virtual offices and PO boxes are NOT accepted. |
B. Ownership & Control Documents
For each Beneficial Owner (25%+ ownership) and Control Person, you must collect:
1. Beneficial Ownership Documentation (Required for all 25%+ owners)
| Document Type | What to Collect |
|---|
| UBO Declaration | Documentation identifying all individuals with 25% or more ownership |
| Ownership Attestation | Signed statement by the control person confirming the ownership structure |
2. Government-Issued ID for Control Persons & UBOs (Choose ONE per person)
| Document Type | What to Collect |
|---|
| Passport | One clear photo/scan of the passport |
| National ID Card | Two photos/scans: front AND back of the card |
| Driver’s License | Two photos/scans: front AND back of the license |
3. Individual Shareholder Passports (Required for all UBOs)
| Document Type | What to Collect |
|---|
| Passport for Each UBO | Clear scan/photo of passport for every 25%+ owner |
4. Proof of Address for Control Persons & UBOs (Choose ONE per person)
| Document Type | Requirements |
|---|
| Utility Bill | Gas, electric, or water bill from the last 90 days |
| Bank Statement | Statement from the last 90 days |
| Government Letter | Official government correspondence from the last 90 days |
| Residence Permit | Current residence permit |
| Passport | Only if it shows the current address |
| National ID | Only if it shows the current address |
| Driver’s License | Only if it shows the current address |
| Company Document | Company-issued document showing the address |
C. Money Movement Business Requirements
If your business involves money transmission, payments, remittances, or cryptocurrency services, you must also provide:
1. Source of Funds & Wealth (Required)
| Document Type | What to Collect |
|---|
| Source of Funds Declaration | Written explanation of where the business funds originate |
| Source of Wealth Documentation | Supporting documents proving the origin of funds (contracts, invoices, etc.) |
2. Business Operations (Required)
| Document Type | What to Collect |
|---|
| Proof of Nature of Business | Documentation demonstrating your business activities and operations |
| Entity Website | Active website URL showing business information and services |
3. Compliance Documentation (Required)
| Document Type | What to Collect |
|---|
| AML Policy | Your company’s Anti-Money Laundering policy document |
| AML Comfort Letter | Letter from compliance officer or legal counsel confirming AML compliance procedures |
Document Quality Requirements
All submitted documents must meet the following standards:
- Clear and legible - text must be readable, no blurry or obscured content
- Complete - all pages of multi-page documents must be included
- Current - documents must be valid and not expired
- Color scans or photos - black and white copies may not be accepted
- Original language - if not in English, certified translations may be required
Important Notes
Virtual offices and PO boxes are NOT acceptable as proof of business address. You must provide documentation showing a physical operating location.
All individuals with 25% or more ownership must provide complete documentation including government ID and proof of address.
Money movement businesses (payment processors, remittance services, crypto exchanges) have additional compliance requirements and must provide all documents in Section C.
