Know the customer.
Understand the transaction.
Anti-money laundering (AML), countering the financing of terrorism (CFT), sanctions and customer due diligence considerations form part of responsible financial services. This public guide explains information that may be requested and the stages of review for an ECB group engagement.
The applicable process depends on the contracting entity, jurisdiction, service and assessed risk. It does not replace the entity’s formal policies or applicable legal requirements, and it is not confirmation of regulatory approval or certification.
KYC — individuals
Identify and verify relevant individuals, including authorised representatives and beneficial owners, using reliable information and appropriate supporting evidence.
KYB — businesses
Establish the legal business identity, ownership and control structure, business activity and authority of the people acting on its behalf.
A clear sequence of review.
Identify the proposed relationship
Explain the service required, purpose of the engagement, countries involved, expected transaction values, currencies, frequency and relevant counterparties.
Collect identity and business records
Provide the requested corporate documents and identification for directors, authorised signatories and relevant beneficial owners. Submit documents through the secure channel agreed with your ECB contact.
Verify ownership and authority
Clarify the ownership chain to the natural persons who ultimately own or control the business, including control through other means. Applicable thresholds and evidence requirements vary by jurisdiction; a single group-wide percentage is not assumed.
Assess risk and resolve questions
Review the customer profile, counterparties, jurisdictions, proposed activity and source of funds. Further evidence, explanations or enhanced review may be required before a decision.
Confirm the decision and next steps
Complete required approvals and contractual documentation before commencing an approved service. An enquiry, document submission or fee payment does not itself confirm onboarding or transaction approval.
Prepare a complete information pack.
The following is an indicative checklist. The relevant entity will confirm which documents, certification, translations and validity requirements apply to your engagement.
Company & legal existence
- Certificate of incorporation or registration
- Current trade licence or business authorisation, where applicable
- Constitutional documents and registered address
- Business profile and relevant tax information
Individuals & representatives
- Valid passport or accepted national identity document
- Residential address evidence, as requested
- Director and signatory details
- Board resolution, mandate or power of attorney, where applicable
Beneficial ownership
- Shareholder register and ownership chart
- Intermediate company ownership records
- Identity information for ultimate beneficial owners
- Trust, nominee or other control arrangements, where relevant
Business & transaction purpose
- Underlying contract, purchase order or invoice
- Buyer, seller and payment-route information
- Financial statements or supporting business records
- Source-of-funds evidence and, when required, source-of-wealth evidence
Review proportionate to the risk.
Sanctions & counterparty screening
Relevant parties and jurisdictions may be reviewed against applicable sanctions requirements. Potential name matches require assessment; a match alone does not establish that two parties are the same person.
Politically exposed persons
PEP status, relevant family or close-associate relationships and related risk factors may require additional review. PEP status alone is not an allegation of wrongdoing.
Enhanced due diligence
Higher-risk circumstances may require more detailed ownership evidence, source-of-funds or source-of-wealth information, independent verification and appropriate senior approval.
Trade-related checks
Documents may be reviewed for consistency across the goods, quantities, pricing, shipment route, counterparties and proposed financial instrument. Unclear or inconsistent information can lead to further enquiries.
Where required checks cannot be completed or a proposed activity is prohibited, the relevant entity may be unable to establish or continue the relationship or process the transaction.
Keep the relationship current.
Ongoing review
Customer information and transaction activity may be reviewed against the understood business purpose and risk profile. Changes in ownership, control, signatories, business activity, jurisdictions or expected volumes should be notified promptly.
Records & confidentiality
Identification, due diligence and transaction records are handled and retained in accordance with applicable legal requirements and the relevant entity’s policies. Access and disclosure are subject to appropriate confidentiality, data-protection and legal obligations.
Escalation & reporting
Unusual activity may require internal escalation and assessment. Reporting to competent authorities is subject to applicable law, including restrictions on disclosing the existence or details of a report. Specific review outcomes may therefore not be available for disclosure.
Clarity before you begin.
Does one document pack cover every group entity?
Requirements depend on the entity, jurisdiction, service and risk assessment. Existing information may need to be updated or supplemented.
Does submitting documents guarantee approval?
No. Documents support assessment. Any engagement remains subject to the relevant checks, approvals and agreed contractual terms.
Why might further information be requested?
Complex ownership, missing records, transaction changes or unresolved inconsistencies can require additional evidence. Your contact can clarify what is needed, subject to legal disclosure restrictions.
Is there a fixed completion time?
Timing depends on the completeness of information, verification results, the proposed transaction and any external counterparties. The relevant team can discuss the status of a specific enquiry.
Prepare for your compliance review.
Ask for the relevant entity’s onboarding checklist or clarification of a document request. Keep your public enquiry brief and exclude sensitive records.
This prepares a local summary to share with your established ECB contact. It does not submit documents or initiate an automated verification.
International reference materials
For general background on risk-based due diligence and AML / CFT principles. These materials do not imply endorsement of ECB or replace local law.
FATF Recommendations Basel Committee: AML / CFT guidance