- Establishing a business relationship with a new client (individual person/legal entity);
- The Company suspects money laundering or terrorist financing;
- The Company has doubts about the veracity or adequacy of documents, data, or information previously obtained for the purpose of CDD.
When verification of identity is conducted after the establishment of a business relationship, verification must be completed as soon as is practical after the business relationship has been established.
The first stage of verification is the collection of data from the client. Once the client is registered on the Cratos platform, they are requested to go through the verification process in order to perform any actions on the platform. We ask the client to indicate:
- For individual persons*: email, passport/ID card, proof of address, and a filled-out AML questionnaire;
- For legal entities*: email, passport/ID card of UBOs/Shareholders/Director/Representative person, PoA (for a representative person), proof of address UBOs/Shareholders/Director company’s documents (the list of documents is provided based on the location), and a filled-out AML questionnaire.
If any of the documents submitted is of poor quality or its validity period has expired, we ask the client to submit a new document in better quality.
Please be aware that:
- Utility bill has to be less than 3 months old;
- Mobile phone bill cannot be accepted as a document;
- Passport/ID card, which expires in a month, is considered not valid.
*Depending on the situation (country of registration, ownership structure, etc.) additional documents may be requested.
During the second stage of verification, we ask the client to indicate his proof of source of funds (for individual person, UBOs/Shareholders)** for the deposits from 500 EUR up to 5000 EUR. The second stage of verification is conducted at the time of a transaction to verify that a payment instrument belongs to the account holder. If a payment card or other payment instrument belongs to a person who is not the owner of the account, such a transaction is put on hold until the appropriate payment instrument is presented or we request a source of wealth confirmation. If the country of registration of the client does not match the country from which the funds are being sent, the Company can ask the client to fill out a questionnaire to confirm the source of wealth. Please note that the second stage is possible only if the first stage had been completed.
**Depending on the situation (country of registration, ownership structure, etc.) additional documents may be requested.
The third stage of verification is valid for when the transaction amount is 5,000 EUR or more. In this case, we always request a source of wealth confirmation (for UBOs/Shareholders)***. Please note that the third stage is possible only if the previous two stages have been completed.
***Depending on the situation (country of registration, ownership structure, etc.) additional documents may be requested.
The fourth stage of verification is requested if a total of monthly transactions exceeds:
- A monthly volume of 15000 EUR for an individual client;
- A monthly volume of 25000 EUR for a legal entity.
The client will be requested to go through a physical face-to-face verification**** and should provide all copies of the documents with an apostille and/or certified by a notary*****.
The list of required documents for a legal entity will be provided by the compliance team.
****If the face-to-face verification is requested, the client will be provided with detailed information.
*****Depending on the situation (country of registration, ownership structure, etc.) additional documents may be requested.