Entity users present more complex due diligence requirements than individuals. This guide covers the specific considerations for business customer onboarding.

Entity Onboarding Challenges

Entities are more complex because:

  • Multiple stakeholders involved
  • Classification determines requirements
  • Controlling persons may need identification
  • More documentation required
  • Ownership structures may be complex

Required Information

Entity Details

  • Legal name and trading names
  • Registration number and jurisdiction
  • Registered and trading addresses
  • Legal form (corporation, LLC, partnership, trust)
  • Date of incorporation
  • Tax residency jurisdiction(s)
  • Entity TIN(s)

Supporting Documents

  • Certificate of incorporation
  • Articles of association/bylaws
  • Register of directors
  • Shareholder register
  • Board resolution authorizing account
  • Proof of registered address
Document Verification

Corporate documents should be verified against official company registries where available. Many jurisdictions provide online registry access.

Classification Process

Determine entity type through:

  1. Self-certification of entity type
  2. Review of financial statements (if available)
  3. Analysis of business activities
  4. Income and asset composition assessment
  5. Documentation of classification rationale

Controlling Person Due Diligence

For Passive NFEs:

  • Identify all controlling persons
  • Collect identification for each
  • Obtain tax residency self-certification
  • Validate TINs for each controlling person
  • Document ownership/control percentages
Passive NFE Requirement

If an entity is classified as a Passive NFE, all controlling persons with tax residency in a reportable jurisdiction must be reported. This creates significant additional due diligence burden.

Ongoing Requirements

  • Annual confirmation of entity status
  • Monitor for ownership changes
  • Update controlling person information
  • Re-classify if circumstances change

Conclusion

Entity due diligence requires structured processes and clear documentation. Invest in staff training and systematic workflows to ensure consistency.

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