*Listed companies: According to Article R561-15 of the CMF, these are “companies whose securities are admitted for trading on a regulated market in France, in another Member State of the European Union, in another State party to the agreement on the European Economic Area, or which are subject to disclosure obligations in accordance with Union law or which are subject to equivalent international standards guaranteeing adequate transparency of information relating to capital ownership, which the person mentioned in Article L. 561-2 is able to justify to the supervisory authority mentioned in Article L. 561-36.”

To validate or invalidate the onboarding, the Compliance Officer conducts additional due diligence. SFS (Spendesk Financial services) will collect additional information.

The documents required are listed below (this is not an exhaustive list) :

The accepted identity documents (PoI) for AO are :

The accepted identity documents for UBO and Legal Representatives are as follows:

Passport characteristics :

National Identity card characteristics :

💡 In France, in 2014, the validity period of an adult's identity card was extended from 10 to 15 years. Therefore, the card remains valid for an additional 5 years if it meets the following two conditions:

Residence permit characteristics :

💡 If the document is expired and being renewed, the client must submit:

Certificate of registration issued by an official UE Registers. The list of official businesses registers by country in the EEA zone is available here.

Certificate characteristics :

If the certificate mentions a collective insolvency procedure, it is necessary to ensure that the legal representative still has the necessary authority to sign the SFS contract, or to approach the appointed administrator to obtain their consent and identification document. This information is available in the official bulletin of the country where the company is registered.

A proof of address

Proof of address accepted :

Proof of address characteristics :

The accepted documents are :

Extract of Beneficial Ownership register characteristics :

In France, any absence or inconsistencies between the submitted declaration and the information on the beneficial owners available must be reported to the registrar of the commercial court via the portal: https://registrebeneficiaireseffectifs.infogreffe.fr/connexion.

The articles are a contract describing the purpose, the governance & rules of the entity.

Articles of association characteristics :

If it's not possible for you to understand the Articles due to the language used, a translation in French or English must be performed via Deepl (paid version) and you can store it as an appendix of the document.

Minutes are a written record that reports what was said or done in a meeting or assembly.

Minutes characteristics:

If it's not possible for you to read the Minutes due to the language used, a translation in French or English must be performed via Deepl (paid version) and you can store it as an appendix of the document.

If the purpose of the data collection is to ascertain the beneficial owners of the entity, the following information must be provided to ensure validity: names, first names, date and place of birth.

In the absence of this information, the client will need to submit the following alternative document:

In an association, the President and, according to the statutes, directors have the status of legal representatives. Therefore, the UBOs will be as legal representative the President and any potential directors.

The accepted documents are :

Certain entities are required to have their accounts audited.

Financial documents characteristics:

For entities with less than one year of operation, the financial forecast for the business activity should be requested as an alternative document.

A power of attorney is a written document (a mandate) that allows the legal representative (the principal) to authorize a third party (the proxy) to carry out operations on its behalf.

Power of attorney characteristics:

In the case of a limited mandate, SFS, which cannot monitor it (as of today) must, prior to the account opening, have the legal representative sign a waiver.

German law provides, in addition to the company's managing directors ("Geschäftsführer"), the possibility of appointing a representative of the company that does not exist in France: the "Prokurist" (authorized signatory), defined in articles 48 et seq. of the German Commercial Code, who holds a general commercial power of attorney. However, the opening of a payment/bank account is not among the automatic rights granted to the Prokurist. However, assuming that operating the account is within the ordinary course of business of the company, the Einzelprokura would be sufficient and no additional power-of-attorney or authorisation would be needed.

Please find them below this article (downloadable files). 🔗