What documents are required for Entity verification?
As of May 2018, we are required by FinCEN to look through entity customers to determine the natural person(s) that are the ultimate beneficial owners (UBOs). UBOs represent both ownership and control over the entity. We run AML and KYC on each UBO that has a 25% equity stake in the entity, as well as on a designated control person (president, director, CEO, manager, etc.) In addition, we run AML on the entities themselves.
Please Note:
All documents and information below are required
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We perform full KYC/AML checks on all equity owners with a 25% or greater stake in the entity.
- We do not take ID cards or driver’s licenses for foreign investors. Passports are required for all foreign investors.
- All documents must be provided in English.
- Each entity’s documents may be written differently; additional information may be required at the discretion of the reviewing NCPS Principal.
- Addresses must be the UBO's legal, residential address. P.O. boxes are not permitted.
- Multi-layered entities: If an entity is owned or managed by another entity, you must collect that entity’s
documents as well. We must have appropriate documents for each layer, until we arrive at the UBOs.
LLC
- Certificate of formation
- Articles of organization
- Operating agreement
- Members’ list and authorized signers’ list (if not included in the documents)
- For each member with a 25% or greater equity stake, as well as for the designated control person, we require their full legal name, DOB, SSN, and residential address.
- For all U.S. individuals that fail KYC or AML, a driver’s license or passport is required.
- A passport is required for all foreign individuals.
CORPORATION
- By-laws
- Certificate of formation
- Articles of incorporation
- Shareholders' list and authorized signers' list (if not included in the documents)
- For each member with a 25% or greater equity stake, as well as for the designated control person, we require their full legal name, DOB, SSN and residential address.
- For all U.S. individuals that fail KYC or AML, a driver’s license or passport is required.
- A passport is required for all foreign individuals.
LIMITED PARTNERSHIP/GENERAL PARTNERSHIP
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Certificate of formation
- Partnership agreement
- LP list and general partner(s) list (if not included in the documents)
- For the GP and for LPs with a 25% or greater equity stake, we require their full legal name, DOB, SSN and residential address.
- For all U.S. individuals that fail KYC or AML a driver’s license or passport is required.
- A passport is required for all foreign individuals.
TRUSTS (REVOCABLE AND IRREVOCABLE)
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The full trust document or a certification of trust.
- For irrevocable trusts, their EIN.
- List of all trustees, grantors (if still living), and protectors, including their full legal name, DOB, SSN, and residential address.
- For all U.S. individuals that fail KYC or AML, a driver’s license or passport is required.
- A passport is required for all foreign individuals, as they will automatically fail KYC.
With regards to trusts, we run KYC and AML on the trustees, and run AML on the trust itself. Depending on the nature and complexity of the trust, we may also run KYC and AML on grantors (if still living) and, if applicable, any other person who may have some control over the trust (e.g., trust protectors).
Please Note
- All documents and information are required.
- We do not take ID cards or driver’s licenses for foreign investors. Passports are required for all foreign investors.
- All documents must be provided in English.
- Each trust document may be written differently; additional information may be required at the discretion of the reviewing NCPS Principal.
- Multi-layered trusts: If a trustee is another entity, you must collect that entity’s documents as well. For each layer we must have the documents, until you drill down to natural persons.
- We run KYC and AML on all trustees, regardless if one is authorized to sign solely.