A know your business review is a reading exercise. Someone in an onboarding team opens a folder, works through it in order, and looks for contradictions. The shareholding in the incorporation certificate should match the shareholding in the ownership chart, which should match the names screened for sanctions, which should match the people who signed the AML policy. When those four things disagree, the application does not get a query. It gets closed, and the firm is told to reapply later.
The pack below is the shape most banks and payment institutions ask for from a trading firm. Names differ, the substance rarely does.
Corporate identity and the ownership chain
Certificate of incorporation, memorandum and articles, current register of directors and shareholders, and a certificate of good standing where the registry issues one. Then the part that decides the file: an ownership chart that runs from the operating company all the way to natural persons, with percentages at every level.
Beneficial ownership is where offshore structures fail. If a holding company in one jurisdiction owns the operator in another and the chain passes through a nominee arrangement, the reviewer cannot resolve the ultimate owner and the file stops. Trusts and foundations are not automatically a problem, but they need the deed and a clear statement of who controls and who benefits. Anything the reviewer cannot verify independently becomes a reason to decline rather than a question to ask.
Licence evidence, in the form the bank can check
A licence certificate PDF is not evidence. A register entry is. Give the exact legal name, the reference number and the register the bank can search, and make sure the name on the register matches the name on the account application character for character. Trading names and brands cause more delays here than anything else, because the reviewer finds a licence for a name that is not the applicant.
Also state plainly which activities the licence permits and which entity in the group performs them. If the licensed entity is not the entity applying for the account, explain why in one paragraph and expect the question to be asked again. Our guide to reading a regulator's public register covers what a reviewer sees when they look you up, and how to check a licence properly shows the same process from a client's side.
Policies that show a functioning control environment
The AML and counter-terrorist financing policy, the KYC and onboarding procedure, the sanctions screening procedure, the client money or client funds policy, the complaints procedure and the record retention policy. What matters is not length. It is that the policy describes what your firm actually does, names the person responsible, and can be traced to a real system.
A reviewer can tell a template from a working document in about a minute. Generic policies with a placeholder still in them signal that the controls are decorative. Reference the tools you use for identity verification and screening, describe your escalation route, and name the compliance officer with their CV attached. See AML basics for trading firms and how sanctions screening works for what those procedures need to cover.
The commercial story and the flow forecast
Banks want a description of the business they can compare against future statements. Expect to provide the business plan, the client markets you serve and the ones you exclude, your pricing model, your marketing channels, your liquidity or execution arrangements, and audited or management accounts.
Then the forecast: expected monthly inbound volume, average deposit size, number of clients, expected outbound payouts, the currencies involved and the countries at both ends. Be honest and slightly conservative. This forecast becomes the baseline for transaction monitoring, and every material divergence from it later reads as a change you concealed. Firms that overstate to look impressive create their own alerts.
None of this is legal advice. Requirements vary by institution and jurisdiction, and structure, licensing and client money arrangements should be settled with your own lawyers and compliance advisers before an application goes in.
Individuals, source of funds, and the questions behind them
For each director and each beneficial owner: passport, proof of address dated recently, CV, and a source of wealth statement supported by documents. Source of wealth is about the person and how they came to have money. Source of funds is about the specific capital going into this company. Both get asked, and the second one needs a paper trail: a sale of a previous business, a loan agreement, dividend history, an investment round with the paperwork.
Politically exposed person status is a screening outcome, not an accusation, and it triggers enhanced due diligence rather than refusal. Declare it. Reviewers find it anyway, and undeclared PEP status turns a routine escalation into an integrity concern.
How to assemble it so it survives a second reader
One folder, numbered sections, a cover sheet listing every document and the entity it belongs to. Certified copies where the institution asks for them, and translations where the original is not in a language the reviewer reads. Consistent legal names throughout, including in the email signature of whoever submits it.
Then keep it current. A pack assembled once and never updated fails the annual review, which is the moment many relationships end quietly. The firms that keep accounts are the ones where onboarding records, transaction history and client balances live in one system that can produce an export on request. That is a large part of what a proper client portal and back office is for, and why KYC records kept in the CRM beat records kept in an inbox.
"Nobody declines a brokerage because the AML policy was two pages short. They decline it because the shareholding on page four does not match the ownership chart on page nine, and now nothing in the folder can be trusted."
— Roman Onta, Executive Director, SINGUARD
Key Takeaways
- A KYB reviewer is looking for contradictions between documents, so internal consistency matters more than volume.
- Licence evidence must point to a public register entry whose legal name matches the applicant exactly.
- Policies are judged on whether they describe the firm's real controls and name a real responsible person.
- Forecast flows honestly, because that forecast becomes the baseline for transaction monitoring afterwards.
Frequently Asked Questions
What is the difference between source of wealth and source of funds?
Source of wealth explains how an individual accumulated their overall assets. Source of funds explains where the specific money entering this company came from and needs supporting documents such as a sale agreement, loan contract or dividend records.
Does a brand or trading name cause problems in a bank application?
It does when the register entry is under a different legal name. Apply in the exact legal name on the incorporation record and the licence register, and list trading names separately as brands the entity uses.
Should we disclose that a director is a politically exposed person?
Disclose it. PEP status triggers enhanced due diligence rather than automatic refusal, and screening tools will surface it regardless. Non-disclosure turns a procedural step into a question about the firm's integrity.
About the Author
Roman Onta is an Executive Director at SINGUARD. He builds the Prop Firm CRM, the Broker CRM, Scalegram and CopySignals side by side with his brother Alex Onta, and he helped on the design of eTrader, the division Alex built and leads. His ground is worldwide payment processing, AML compliance and the corporate structures brokers are built on, work the two of them carry together, shaped by executive roles in the UAE and international corporates. He lives and works in Dubai for most of the year. Meet the executive duo leading Singuard's five divisions.