Key takeaways
- Corporate, business, compliance and personal documents make up the file.
- Personal documents usually need certification and sometimes apostille.
- Source of funds and wealth must be explained and evidenced.
- Consistency across every document speeds up review.
Corporate documents
- Certificate of incorporation, constitution, registers.
- Group structure chart down to the ultimate beneficial owners.
- Board resolutions approving the application.
Business and compliance documents
- Business plan with three-year financial projections.
- AML/CFT manual and risk assessment.
- Compliance manual, risk management policy, complaints procedure.
- Client agreement, risk disclosure and order execution policy.
- IT, outsourcing and business continuity descriptions.
Personal (fit-and-proper) documents
- Certified passports and proof of address.
- Detailed CVs and professional references.
- Police clearance certificates.
- Bank references and source of funds/wealth evidence.
- Personal questionnaires required by the regulator.