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Please note This article is specifically intended for our partners who are Independent Asset Managers (IAMs) |
Q: What is the Standard Funding Threshold (SFT) initiative?
A: The Standard Funding Threshold initiative by Saxo Bank aims to enhance AML/KYC processes and boost efficiency in handling Source of Funds (SOF) documentation. It introduces a tailored approach to reviewing SOF documentation based on individualized thresholds set for each end-client.
Q: Why is Saxo Bank implementing the SFT initiative?
A: The SFT initiative addresses inefficiencies in the existing process where end-clients were asked to provide SOF documentation for anticipated deposits. The new approach triggers a SOF review only when an end-client surpasses a specified, individualized funding threshold, improving accuracy and efficiency.
Q: How will the SFT be applied and what happens when an end-client exceeds their funding threshold?
A: Each end-client will have a funding threshold applied based on their individual circumstances and supporting documentation. If an end-client's net funding (deposits minus withdrawals) breaches their individualized threshold, Saxo will review their SOF documents. If documentation is insufficient, an event-driven renewal process will be triggered on SaxoConnect, requiring updated documentation.
Q: How can I differentiate between transaction alerts related to the SFT project and regular BAU alerts?
A: Partners can differentiate by checking the expiry date. Regular business-as-usual alerts have a deadline of 35 days, whereas alerts linked to the remediation exercise have an extend deadline until end of February.
Q: How are thresholds calculated and made visible to end-clients?
A: Thresholds are calculated based on the SOF documentation received and we intend to make it visible on SaxoConnect. More information will follow on when and where it will be shown within SaxoConnect.
FAQ on end-client Outreach for Source of Wealth / Source of Funds
Q: What are the key deadlines for the SFT project?
A: For private end-clients the following deadlines will apply.
- 31st of October 2025: All event-driven renewals will be initiated on SaxoConnect
- 31st of January 2026: Partners deadline for making the last submissions
- 27th of February 2026: Saxo Bank deadline for processing partner submissions
- 28th of February 2026: Funding restrictions applied to end-clients with insufficient documentation
- 2nd of April 2026: Termination notices sent to end-clients
- 3rd of June 2026: Termination & Liquidation of positions of incompliant end-clients
Q: Why now and what is the reason for urgency?
A: In today's fast-changing financial world, keeping up with ever-changing compliance and regulatory framework is essential. The new SFT framework offers better insights into customer deposits and helps determine when a new Source of Funds (SOF) request is needed. We are committed to compliance and working closely with regulators to ensure our methods meet highest standards. This is part of the bank's obligations under applicable AML/CFT regulations to perform “Know Your Client” (KYC) measures
The reason for sensitivity of this exercise is our manual checks have shown that some of the end-client’s files do not have complete SOF documentation. Unexplained deposits or missing details can lead to transaction alerts for clients, which usually require being handled within 35 days to avoid restrictions or closures. Recognizing that this may require extra effort on your part to gather the necessary documents, we are offering additional time to resolve the data gaps, while staying within our time commitments towards our regulators.
Therefore, we encourage you to promptly review outstanding documentation for the end-clients in scope and help submit the outstanding documentation. This proactive approach will help avoid last-minute challenges and ensure all documentation meets compliance standards. Thank you for your cooperation and understanding as we maintain the integrity of our operations together, and at the same time offer end-clients with tailored SOF framework as a future process.
Q: Is it possible to submit data while the account is restricted?
A: Yes, the account will be restricted for one month, with incoming funds automatically returned. We strongly encourage partners to submit any outstanding details promptly within this restriction period. Please keep in mind that the Saxo renewal team must also review the additional submissions during this period, while adhering to the overall project deadlines. To ensure timely completion and prevent the risk of account closures, which we naturally wish to avoid, it is vital to answer all questions as clearly and comprehensively as possible. Providing all relevant details and supporting documentation will help minimize the need for additional information requests from both sides.
Q: How does the SFT project differ from previous remediation efforts?
A: Unlike prior remediation efforts with strict deadlines, the SFT project will initiate all cases simultaneously with an overall deadline, allowing partners to manage capacity and prioritization more effectively.
Q: Does Saxo Bank conduct outreach for all end-clients?
A: No, Saxo conducts outreach when documentation already on file is insufficient to meet KYC requirements related to SoW/SoF. Outreach is also necessary if applicable requirements have been revised or the end-client's circumstances or use of Saxo’s products and services have changed.
Q: Why can’t the outreach wait until the end-clients’ next periodic due diligence (ODD)?
A: Due to the critical nature of SoW/SoF information in relation to Saxo’s KYC obligations, the outreach and update are required immediately and cannot be postponed until the next ODD cycle.
Q: Can you provide an example of a situation requiring end-client outreach?
A: An example is a married couple holding a joint account. Upon account opening, Saxo was informed that their source of wealth was savings from their income. However, their lifetime funding significantly exceeds plausible savings based on their income. Saxo needs to understand the reasons for this deviation, which may include inheritance or large insurance payouts, necessitating outreach to obtain clarity on the actual sources.
Q: What documentation might Saxo request from end-clients?
A: Documentation requests will align with the declared Source of Wealth (SoW) for individuals. For example, Saxo may request salary slips or tax statements if wealth is declared from salary. Alternative documentation is often acceptable, especially if there are multiple sources of wealth such as inheritance or property sales.
Please review the following article explaining the Requirements of Source of Funds / Wealth declarations
Q: Will my clients be expected to submit additional information not related to SoF?
A: To ensure accuracy of the client’s data, please follow these steps:
- Check Auto-Populated Details: Examine the auto-populated details within the flow. These details have been pre-filled based on available information with Saxo, but it is important to verify their accuracy which might also help the clients.
- Identify Critical Changes & Confirm Details: If you notice any discrepancies or critical changes that need to be made to the auto-populated information or responses, please feel free to make the necessary adjustments. Once you are confident that all the information is accurate and up to date, confirm the details within the Saxo flow.
- Proceed to Source of Funds Section & Upload Documents/information: Continue to the Source of Funds section. Here, you'll be required to upload the necessary documentation and information to support the source of funds of the client.
Q: What happens if an end-client’s source of wealth or funds is complex?
A: Saxo may require additional details, especially for end-clients with a complex wealth structure, such as income accumulation over a long career, inheritance, share disposals, or company sales. This complexity necessitates more detailed information for accurate assessment. We kindly ask you to provide a detailed explanation of the client’s circumstances supported by relevant documentation.
Q: How can I provide an explanation about the Source of Funds (SoF) for my client if the system does not support free text input?
A: We highly encourage our partners to submit detailed written explanations about clients' sources of funds or wealth, especially for clients with multiple income streams or who are retired. While we are working on updating the system to support free text input, you can attach your comprehensive write-up as a separate Word or PDF document and upload it along with all other relevant documents during your first submission.
Providing detailed explanations in writing will allow our KYC team to better understand the client’s financial circumstances and enable them to take a programmatic approach in completing the assessment, where possible.
Q: What steps will be taken for end-clients with insufficient SOF documentation?
A: For end-clients with insufficient SOF documentation, Saxo will initiate a renewal process requesting additional documentation. Our partners are kindly requested to upload necessary documents via the Renewal tool for private end-clients on SaxoConnect. Saxo can also provide a bulk upload solution for partners managing a large number of clients within the remediation scope. If you require such solution, please contact your designated account manager.
Q: What should partners do if an end-client’s documentation is insufficient?
A: Partners should upload necessary documentation via SaxoConnect. Saxo assumes partners have the required documentation, which might not have been captured to a satisfactory degree from time of onboarding or in previous renewal cycles.
Q: Will corporate end-clients face similar processes?
A: Internal reviews for corporate end-clients are ongoing. Early indicators suggest fewer issues with corporate end-client documentation compared to private end-clients, which is positive. The process for corporate end-clients will be initiated through the Case management module.
Q: What regulations are guiding Saxo Bank's KYC measures, specifically in relation to SoW and SoF?
A: For end-clients in the Netherlands, Saxo Bank's KYC measures are notably based on articles 3 (2) d, 8, and 9 of the Wwft. Additionally, Saxo regularly updates its internal requirements to align with laws, regulations, market best practices, expectations, and standards set by key stakeholders such as regulators.
Q: Where can I find more information or ask questions about the project?
A: For inquiries concerning scope and timelines, partners are encouraged to reach out directly to their designated account manager for assistance. Should there be any questions pertaining to the end-client requirements or documentation, these should be addressed by contacting the Local KYC Support Team. Partners can do so by creating a case that includes all relevant details.
- Subject line: SFT project
- Client ID
- Clear description of what is needed
Please find the instruction on how to create a case here
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