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What You Need to Submit

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Company Basics

  • Exact legal name (must match formation documents)
  • Physical operating address (NO virtual/PO Box/registered agent addresses — use UBO’s home address if remote)
  • Formation document with filing stamp
  • Registration / Tax ID number (EIN, ITIN, RFC, or VAT)
  • Business email, phone, and functional website (if no website: provide invoices or marketing materials)
  • Entity type (LLC, Corporation, Partnership, Investment Fund, Foundation/NPO, Trust, Sole Proprietorship, DAO, Government Body)

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Business Description

  • Industry type (NAICS code — regulated industries need license proof)
  • Nature of business — minimum 250 characters covering: products/services, target market, geographic areas, business model
  • Account purpose (standard vs. high-risk — high-risk purposes like third-party transmission or tax optimization require explanation)
  • Source of funds and source of wealth (high-risk sources like pension funds, third-party funds, or loans require proof)

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Financial Details

  • Estimated annual revenue
  • Anticipated monthly fiat deposits and withdrawals
  • Public company status
  • Third-party payout intent
  • If volume exceeds $1M/month: provide bank statements and invoices
  • All UBOs (25%+ ownership): full name, DOB, nationality, residential address, government-issued photo ID (unexpired), proof of address (utility bill <90 days), SSN/ITIN (US residents)
  • At least 1 Authorized Person
  • Person with Significant Management Control (CEO/CFO/COO — required even without ownership)
  • Directors (non-U.S. companies only)
  • Corporate shareholders: legal name, country, registration number, ownership %

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Supporting Documents (by entity type)

  • All entities: Proof of business address, proof of source of funds, shareholder registry (or cap table/org chart), formation document with filing stamp, control structure document
  • Investment Funds: Prospectus, AML Comfort Letter, Fund Structure Chart
  • Foundations/NPOs: Tax Exemption Letter, Annual Reports
  • Trusts: Trust Agreement
  • Sole Proprietorships: Business License, DBA Filing, Tax Filings
  • DAOs: Voting Records
  • Regulated entities (MSB, PSP, DASP): Current license + AML & Sanctions Policy

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Document Validity

  • Proof of address / bank statements / financial statements: 90 days
  • Tax returns: 1 year
  • Formation documents: No expiration
  • Government ID: Must not be expired

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Pre-Submission Checklist

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Always Required

  • Company name, physical address, formation document, Tax ID
  • Business description (250+ chars), industry selection, account purpose
  • Source of funds, monthly volume estimate
  • Business activity docs (invoices or business plan)
  • UBO info + government ID for all 25%+ owners and control person

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Conditionally Required

  • DBA documents (if operating under different name)
  • Proof of address (if address flagged)
  • Investment funding agreement (if source is investment)
  • Third-party fund explanation + funds flow diagram (if handling others’ funds)
  • Bank statements (if monthly volume > $1M)
  • Org chart (if complex ownership)
  • Licenses (if regulated industry)

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How to Avoid Common RFIs

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The Big Three

RFI TriggerHow to Prevent It
”Substantiate nature of business”Upload 3–5 client invoices upfront. If pre-revenue: Pitch Deck or Business Plan. If no website: marketing materials.
”Virtual address detected”Use UBO’s residential address as operating address + upload a utility bill immediately.
”Website doesn’t match entity name”Upload signed Org Chart or DBA certificate. If parent/sister company owns the domain, include an intercompany service agreement.

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High-Value Triggers

RFI TriggerHow to Prevent It
Third-party funds / flow of fundsWrite a simple statement: “Funds originate from [X], enter via [Y], used for [Z]. We do/do not handle 3rd party funds.”
High volume (>$50K–$2M/mo)Upload primary bank statement showing balances or incoming flows.
Investment/VC source of fundsUpload SAFE Agreement or LP Agreement immediately.
Broken/template websiteEnsure no dead links, lorem ipsum, or default social media icons.
Complex UBO structureProvide org chart signed/dated by a lawyer or CPA.
Regulated activity (OTC/Lending/Trading)Provide license or detailed exemption explanation.

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RFI Prevention Checklist

  • 3–5 Client Invoices (or Business Plan if new)
  • Utility Bill for operating location (home address if remote)
  • Signed/dated Org Chart (if complex structure)
  • Flow of Funds Statement (1-page PDF/Word)
  • Domain Ownership Proof (if entity name ≠ domain name)
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