Customer Due Diligence Procedures

KYC/AML policy in short

Our KYC/AML policies (on anti-money laundering, sanctions, and anti-bribery and corruption) aim to ensure that we and our clients (the investment entities we service) comply with all relevant legislation. Furthermore our policies are aimed to identify and mitigate risks identified by us that might endanger our aim to comply with these legislation.

Before being accepted as a investor in any investment entity administrated by us, please complete our KYC/AML procedures and provide us with the information/documents as stated below.

 

No hard copies

Hard copies of the subscription form or supporting documents are NOT required. Please send your documents to both info@confidon.nl and to your contact person at the investment company.

 

Natural persons

 

European residents

 

Documents to be submitted:

 

The funds should originate from an bank account with a bank that has adequate anti terrorist financing / anti money laundering policies and procedures in place. Funds from banks located in countries with poor KYC standards and countries identified as 'non-cooperative' in the fight against money laundering and terrorist financing, will not be accepted. In case we cannot obtain enough assurance that the bank in question has adequate procedures in place, the monies will be returned.

 

For subscriptions made by natural persons the funds should originate from an account registered in your own name. We will check this upon receipt of transfer. If you are unable to make a transfer from an account held in your own name, please email us and we will contact you to make alternative arrangements. 

Upon receipt of the investment amount we will perform final identification checks and subsequently confirm your investment.

 

 

Overseas investors

 

Documents to be submitted:

 

The funds should originate from an bank account with a bank that has adequate anti terrorist financing / anti money laundering policies and procedures in place. Funds from banks located in countries with poor KYC standards and countries identified as 'non-cooperative' in the fight against money laundering and terrorist financing, will not be accepted. In case we cannot obtain enough assurance that the bank in question has adequate procedures in place, the monies will be returned.

 

For subscriptions made by natural persons the funds should originate from an account registered in your own name. We will check this upon receipt of transfer. If you are unable to make a transfer from an account held in your own name, please email us and we will contact you to make alternative arrangements. 

Upon receipt of the investment amount we will perform final identification checks and subsequently confirm your investment.

 

Organisations

 

Documents to be submitted:

  1. Signed subscription form
  2. Company extract from the Trade Register, Chamber of Commerce or comparable source.
  3. List of shareholders recorded in an official document e.g. the shareholders register
  4. Copy of the official (signed) articles of memorandum
  5. Copy of passport/other ID document of the director(s) with signature visible
  6. Copy of passport/other ID document of the ultimate beneficial owner(s) (UBO's). For this purpose, “ultimate beneficial owner” is the natural person or persons who ultimately own, control or influence a client for 25% or more (of the shares, voting rights, etc.)
  7. Completed self-certification form to establish tax residence. Please note that organisations with, or with UBO's that do have a 'US-person' status, are not accepted as investor by most of our clients.
  8. In case of one or more entities exist between the organisation and a UBO, documents mentioned under 2 to 7 are needed for every entity.
  9. Additional documents may be required and you will be advised if this is the case. 
  10. Organizations owned, controlled or influenced by Politically Exposed Persons (PEP's), including close relatives, additionally are required to provide documents specifying the source of funds/source of wealth.

 

The funds should originate from an bank account with a bank that has adequate anti terrorist financing / anti money laundering policies and procedures in place. Funds from banks located in countries with poor KYC standards and countries identified as 'non-cooperative' in the fight against money laundering and terrorist financing, will not be accepted. In case we cannot obtain enough assurance that the bank in question has adequate procedures in place, the monies will be returned.

 

Upon receipt of the investment amount we will perform final identification checks and subsequently confirm your investment.

 

CRS forms

Under the Common Reporting Standards laws and regulations, we have to determine your tax status. In short, this means that you must fill in a form on which you must state whether you are also liable for tax in a country other than the Netherlands or your home country. Various forms are available for individuals and organizations:

CRS self certification form individuals

CRS self certification form entities

References