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📃 FAQ - our KYC process
Updated over 9 months ago

✨ As a Spendesk customer / entity, you might be undergoing a periodic review or an onboarding collect of documents.

We have tried to recap a few questions on this process and their answers!

Read below 👀

General questions

What are the different reasons for which a collect of documents might be required?

  1. Periodic reviews, for entities who have already been validated and are already using Spendesk. These are mandatory, and required by our banking partner.

  2. Upgrade to a new banking partner or to Spendesk Financial Services.

How often do I need to update my documents?

It can range from every year to every few years, or every time there is an upgrade.

How should the activity of the company be presented?

The activity of the company can be understood by by cross-referencing sources of information like a commercial register extract or online resources.

It can also be appreciated through answering the following questions :
1. What is the company selling ?
2. Who are the company’s customers ?

What do you mean by 'source of funds' ?

Source of Funds (SOF) is a term used to describe the origins of money that an organization uses to finance its operations.
ex:
For trading companies = Income generated by the activity
For charities = Donations

What do you mean by 'legal representatives'?

The legal representatives are all the people that can act on behalf of the company.

ex:

UK ➡️ All the individuals with a role of Director that can be found on CompaniesHouse in the section People > Officer.

What do you mean by 'Beneficial owner'?

Beneficial owner refers to the natural person(s) who ultimately own(s) or control(s) a customer and/or the natural person on whose behalf a transaction is being conducted.

It also includes natural persons who exercise ultimate effective control over a legal person or arrangement. A beneficial owner is always a physical person.

What do you mean by 'Extract from the company register'?

A document dated less than 3 months from the local business register.

ex:

for France: Registre du Commerce et des Sociétés/Business Register https://www.infogreffe.com/

What do you mean by 'Proof of ID'?

A copy (front/back) of the ID card OR

A copy of the 2 pages (top/bottom) of the passport

Maiden / married name

Maiden and married name need to be screened.

Latest audited financial statements

If and only if the company is not required to have their financial statements audited, we can accept unaudited financial statements.

Which countries can be onboarded on Spendesk financial services?

We can now onboard the following countries via SFS (Spendesk Financial Services): 🇫🇷 France 🇩🇪 Germany 🇪🇸 Spain 🇮🇪 Ireland 🇦🇹 Austria 🇵🇹 Portugal 🇧🇪 Belgium 🇳🇱 Netherlands 🇮🇹 Italy 🇱🇺 Luxembourg 🇱🇺

Note: if you need to open an entity or wallet in the UK, you cannot be onboarded on Spendesk Financial Services for now.

How long does it take to validate an entity?

48 hours or more depending on the type of company, documents and current backlog of our KYC teams

You asked a personal POA of our CEO. We cannot provide it.

Why do you need it ?

We need it because in the our process against money laundering, an individual might be involved on a personal or a professional level.

We have to check their personal information as well.

Why do you need a bank letter?

This is because your company is <1 year and we just need to control that your bank is indeed holding your account(s).

Do you accept a French ID that's expired?

We do take into account the 5-year extension announced by FR authorities.

Our director has changed, do you still need their Proof of ID?

We just need the POI and POA of this new director.

Within the registration flow on Spendesk Financial Services, we can only register executives as individuals. How can we provide information for an executive who is a legal entity? What are the documents we need?

If a company X has in its board another entity (Y), by default we consider all the natural persons sitting in Y's board as relevant representatives of the first X company.

Thus, we will fill the KYC application with their names and personal details.
In order to do so, we need the KBIS of the company Y, too.

For the 'address of legal resps' field: does it have to be the personal address?

Yes: we need documents proving details on the personal address of the person (in the process against money laundering, we have to check on both personal and professional responsibility of the stakeholders)

About our document-collection tool, 'Collect' and our periodic review

We use Collect to request missing documents. In the eventuality of a periodic review, for example, you might receive an email from us, sent by collect@spendesk.com.

What email address will the Collect request be from?

What email will the collect email be sent to?

The Spendesk Account Owner
(You can check their name in Settings > Members on Spendesk).

I am the Account Owner and I haven't received the email.

Check in your emails for an email from : collect@spendesk.com and if you haven't received it, contact support@spendesk.com.

If we have any issue or question left unanswered with this FAQ, can we reply to the Collect email?

Of course!

Can I have a deadline?

We made sure to provide enough time for the documents to be provided, but if you require more time, contact us with the reason why and your case will be reviewed as soon as an agent is available.

If we notice a mistake in the Collect process (wrong email), what is the process to let you know and send back the email to the right person ?

In this case please contact us at support@spendesk.com or reply to the email so that we can help.

I think there's a bug with the Collect platform?

In this case please contact us so that we can open a bug ticket.

Required documents and explanation

Proof of Identity

It's a copy (front/back) of the ID card or a copy of the 2 pages (top/bottom) of a passport.
The copy of the document must be in color, very clear and have no defects that could make the inscriptions unreadable (reflection, trimmed part...).

Proof of Address

A proof of address dated less than 3 months old from the following list:
- Bank statement (no credit card statement);
- Gas, electricity, water and internet bills (no telephone bills);
- Letter from a recognized public authority.

Bank letter

It's a letter from your bank attesting that it maintains your company's bank account.

Proxy

It's a delegation of power signed by a legal representative authorizing somebody to act on behalf of the company.

SOW

1) How was the company originally funded?

Source of funding

2) How is the company currently funded?

Ultimate Beneficial Owner declaration

The Ultimate Beneficial Owner declaration, which is an official document declared to the specific country's register, mentioning the significant owners of the company, normally owning 25% or more of the shares.

Shareholding structure*

Official document showing the complete shareholding structure of the company: organization chart/capitalisation table/shareholding attestation dated and signed by a director, register of shares for every shareholding company... ((needs to be dated & signed by a legal representative or a reliable third party such as attorney, notary, external accountant).
You can find an example on the screenshot below this table.

Signature

Signature on the KYC form

E-mail

E-mail address of the signing director

Residential address

Residential address of the person mentioned (no document needed)

Date of birth

Date of birth of person mentioned (no document needed)

Nationality

Nationality of person mentioned (no document needed)

*Shareholding structure

This is a visual example of a shareholding structure being dated & signed.

We need the entire shareholding structure (for example, if a company has shares in the company the KYC is about, we also need its shareholding structure).

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