Fiduciary services
Client checks: explaining ownership and the source of funds
Sources checked:
Preparing the supporting evidence early helps fiduciary work proceed in an orderly way.
The procedure
For services subject to Cyprus anti-money-laundering requirements, the provider identifies and verifies the client, establishes beneficial ownership and understands the purpose of the relationship. Anyone acting for the client must also have their identity and authority checked. The extent of the checks depends on risk, and records must be kept up to date.
What deserves attention
A bank balance does not necessarily explain where the money came from. Depending on the transaction and risk, supporting evidence may include employment income, sale proceeds, dividends or inheritance documents. Explain the underlying event and how the funds reached the account. Additional questions can arise during the relationship; initial onboarding is not the end of the checks.
Prepare for your consultation
Organise an ownership chart, current identification, authority documents and a short explanation of the proposed transaction. Agree a secure method of sharing supporting records. Raise unusual payment arrangements early and allow time for verification before setting completion dates. Where required checks cannot be completed, the provider may be unable to proceed.
General information based on the sources checked on the date shown, not advice on a particular matter. Requirements depend on the facts and may change. Practical preparation suggestions are not an exhaustive statement of legal obligations. Legal disclaimer.
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