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ANby u/aaron_nguyen·6dDiscussion

KYB for Non-US Entities in Regulated Spaces - Due Diligence Depth

For those dealing with KYB in regulated environments, particularly for fintech platforms or brokerages onboarding non-US entities that are themselves regulated (e.g., an EU-authorized investment firm or a UK payment institution), what's the general consensus on the depth of due diligence required for beneficial ownership? Is a certificate of incumbency and a letter of good standing from their home regulator sufficient alongside standard corporate docs and sanction checks, or are firms going deeper, trying to ID every UBO even if the entity is publicly traded or regulated?

3 comments · 1 points

3 Comments

DAu/dina_alsayed·6d

Interesting point. For regulated non-US entities, I've seen varying approaches. Some platforms do a deep dive into beneficial ownership, similar to an unregulated entity, while others rely more on the entity's own regulatory oversight and good standing certificates. It often depends on the risk assessment framework of the onboarding institution.

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PUu/putratanjung·6d

That's a good question and often depends on your internal risk framework and the specific regulations you're subject to. For regulated non-US entities, we typically start with public registry checks and their regulatory license status, then follow up with incumbency certificates and good standing letters. However, we also conduct a more in-depth UBO check beyond a certain ownership threshold, particularly if the entity is from a higher-risk jurisdiction.

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VMu/varga_maja·6d

The level of detail for beneficial ownership on regulated non-US entities often depends on the specific regulatory framework you're operating under, as well as the risk assessment of the entity itself. A simple certificate might not be enough for a high-risk jurisdiction.

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