KYC Policy

Before selling some selected services, by law, we are obliged and entitled to identify the Client by verifying the necessary identification documents, proof of Client residency, holdings in companies, etc.

Therefore we carry out Know Your Customer (KYC) procedures at the time of entering into the Service and regularly thereinafter according to the law and principles set by us. We are not entitled to render the Service unless all identification and KYC requirements have been met. Should it appear after purchase on the Website, that we are not able to provide the selected service, we shall apply a credit to the Customer’s original method of payment within, a certain amount of days.

According to the Money Laundering and Terrorist Financing Prevention Act in force in the Republic of Estonia and other legislation in force in the European Union, institutions are required to identify their customers, as well as collect, verify and update their customer data on a regular basis. Customer data must be reliable and up-to-date. In other words, we must be confident in our customers and adhere to the principle: know our customers.

In order to enter into a customer agreement, an individual must submit the following documents:

  • First name
  • Surname
  • Passport number
  • Identity number
  • Address
  • E-mail address
  • Phone number

The company reserves the right to request additional documents if necessary (confirmation of residence, residence status, existence of e-residence, data on tax residence, data on citizenship).

The client submits a copy of his identity card, which must contain the following information:

  • Owner’s photo
  • Document number
  • Full name
  • Date of birth
  • Sex

The document must be valid and not damaged.

A legal entity must submit:

  • Extract from the commercial register, registration certificate or other documents accepted by MINUFIRMA, which confirm the legal capacity of the legal person
  • If the above documents are not sufficient to determine the legal capacity of the legal entity and its legal representative, the Company reserves the right to request additional documents: articles of association, information on the members of the company’s control or management bodies, address of the company’s actual location
  • Details of founders, shareholders, members of the supervisory board
  • Documents certifying the right of representation of a legal person and the period of validity of the right of representation
  • Details of the beneficial owner

The company has the right to ask additional questions and ask for any additional information that may be necessary to carry out the IOC procedure, including the determination of the beneficial owner.

Only a private individual can be a real beneficiary

  • directly owns the company: the person owns more than 25% of the share capital
  • indirectly owns the company: the person owns another company or several other companies which own more than 25% of the share capital of the company in question
  • who controls the enterprise in another way: the person ultimately influences the enterprise, regardless of the shares, units, voting rights or ownership, or the direct or indirect nature of its effects
  • If the beneficial owner cannot be identified, the member of the highest management body, i.e. the beneficial owner, is indicated as the beneficial owner.
  • chairman of the company’s management board or supervisory board
  • in his absence, all members of the management board or supervisory board. If the management body consists of five members, priority is given to the members who have a greater right of representation (information is presented on the B-card of the Commercial Register)
  • in the presence of the supervisory board, the beneficial owner shall be the five members of the supervisory board who participate most in the strategic decision-making of the company and in the day-to-day operations of the company, its transactions, and financial relations.