Identity
Identity cards, passports and residence permits of the natural persons in the file.
0208Customer due diligence
Knowing who is in front of you, and who decides behind them.
Due diligence is more than a copy of an identity card. It means tying the person in front of you to a known entity, working back to whoever really controls it, and keeping the trace of what established that.
01What the law asks
Three questions before any relationship.
The law does not ask for documents, it asks for answers. AML Company arranges the file around those three questions rather than around a list of boxes to tick.
01
Who the client is
An entity, not a name. The file starts from the company number and the CBE record supplies the name, the legal form, the registered office and the NACE. The legal data comes from the official source, so an outdated name shows up instead of being copied across.
02
Who controls it
The beneficial owners, natural persons, with their share of the capital or the nature of their control. A company held by another company is not an answer: you work back to the people.
03
What the client came for
The purpose and nature of the relationship, which set what will count as normal afterwards. Without that answer no transaction can be called unusual, and ongoing monitoring loses its reference point.
Client file · Active
Beprosoft Venture SRL
Financial health87/100
CBE
0675.566.990
TVA
BE0675566990
NACE
62.010
Form
SRL
Registered office
Bruxelles
Risk
Low
12.04
Score updated+4 pts · CBSO (NBB) filing
02.04
UBO confirmedUBO register · FPS Finance
18.03
FSMA report generatedSigned PDF · 3 pages
02Beneficial owners
What the file keeps on each person.
The fields below are not a form designer's preference: they are what a report to the financial intelligence unit requires later. Collecting them at onboarding saves chasing a date of birth on the day you have to file.
- 01Surname, first name, date and place of birth
- 02Country of birth, nationality, country of residence
- 03Identity document type and number, expiry date
- 04Full address, with box and country
- 05Share of capital held
- 06Role within the company
- 07Political exposure
Zero per cent is a valid answer
A beneficial owner by control, senior manager or control by other means, holds no share at all. Refusing the value zero would make that category impossible to report, and it is precisely the one that matters when ownership is fragmented.
03Supporting documents
Four categories, signed storage.
Every document gets a category and hangs off the client, the company, the beneficial owner or the file. Files never pass through the application: the browser puts them straight onto encrypted storage through a signed, short-lived URL.
Company
Articles of association, official publications, share register, ownership chart.
Contract
Engagement letter, mandate, the agreement the business relationship rests on.
Other
Proof of address, evidence of the source of funds, anything asked for under enhanced due diligence.
04Remote verification
When the person is not in the room.
A relationship that starts remotely needs more than a scan received by email. AML Company opens an identity verification the person completes themselves, from their own phone, and the result comes back into the file.
- A short-lived link, or a QR code to present, with no account for the person being verified to create.
- Verification through itsme for Belgian residents, or through an identity document with a liveness check.
- The result hangs off the beneficial owner concerned, with its date, and stays available afterwards.
- A verification can also be opened on its own, outside any file, for a one-off check.