20.03.2024 Checklist of requirements for onboarding new corporate clients

Minimum Corporate Onboarding requirements

Under the Prevention of Money Laundering and Financing of Terrorism Act (Wwft), Saxo Bank is required to conduct client due diligence on the clients with whom it establishes a business relationship. This includes ensuring the identity of its clients, the source of their funds and wealth and understanding their capital and ownership structure.

Based on Saxo Bank's Customer Due Diligence policy, we are obliged to complete additional questions when opening an account. Depending on your responses, our CDD departments may reach out for further clarification.

Please be aware that sections 1-8, in the opening form, must be completed as they are mandatory to fill out.

We kindly request you to complete the Opening form based on the following minimum requirements:

• Filling in the LEI code, which can be obtained from the Chamber of Commerce. For more info about the LEI code requirement (issued vs expired), please read this article
• Enter the NACE code, which can be found at the tax authorities or via the provided link.
• Ensure that the answers regarding the FATCA status of your company in Part 4 and Part 6 of the opening forms match.
• We would require the full name, date of birth and nationality of the authorized board member(s) and the UBO(s) of the Legal entity;
• Detailed elaboration of the source of funds / wealth (kindly refer to next section) in order to verify the plausibility and mitigate the risk related to Financial Crime.
• If you intend to claim American tax benefits under Part 5, kindly complete form W8-BEN-E (if applicable).
• Please sign the opening forms with a pen as representatives/authorized representatives or digitally with, for example, the DocuSign program.

Margin Lending activation

Please refer to the enclosed help page and documents if you wish to apply for Margin Lending products (both Margin lending application + SFTR forms have to provided).

US relief at source

To comply with the Internal Revenue Service (IRS) regulations, Saxo must confirm that none of our clients trading or receiving income from U.S. securities are U.S. residents. 

If your clients intend to trade U.S. securities for the first time, they are requested to complete a W-8BEN form. This document acts as a certification of their non-U.S. citizenship status, as required by specific U.S. tax laws.  

Please refer to the following help page to access the respective documents.

Please ensure the preparation of supporting documentation during the onboarding process, include the following

Identification and Verification

• Proof of business address if it differs from the registered address (e.g., a company bank statement or a utility bill less than three months old and issued in the company's name).
• Kindly provide copies of passport or National ID card (front and back) for each beneficial owner with more than a 25% interest in the company and for directors. As part of our commitment to enhancing security measures and ensuring the authenticity of submitted documents, we no longer accept IDs or passports that contain watermarks, any covered parts and/or insufficient image quality.
• Attach proof of residency if residing abroad - a utility bill less than three months old that clearly shows the date, name, and address of the applicant corresponding to this on the application.

Ownership and governance documents

• Most recent copy of articles of association and extract from the Chamber of Commerce.
• Organization chart for complex group structures or in case if we have identified any discrepancies, additional elaboration is required with respect to the structure and business activities.
• Please include the most recent “certified” UBO extract from the Chamber of Commerce. Screenshots of UBO registrations with the Chamber of Commerce will not be accepted. Ensure that this proof is not older than 3 months. You can easily order a certified KVK extract from the UBO register through Mijn KVK. For more information, please visit: https://www.kvk.nl/ubo/inzien-gegevens/ 
• If there is more than one shareholder, an additional document is required, such as a shareholder register or a signed and dated organogram.
• For companies with a STAK structure, a certificate holder document is necessary.
• If STAK/stichting is part of the ownership structure, please provide the purpose for its inclusion.

Source of Funds and Wealth

• Source of Wealth form with supporting documents. Kindly refer to the next section for an overview of possible documents that may be obtained based on the applicable sources of income.
• The most recent (audited) annual accounts (profit and loss account) of your entity. If the financial statement for the year 2023-2024 is not available, we kindly request an explanation for its unavailability, along with the reasons for any delay in filing.

Requirements of Source of Funds / Wealth declarations

Below is an overview of (possible) documents to be obtained during the onboarding process. Kindly note that this may vary based on the complexity of the cases, and this list is not exhaustive.

Source	Documentation that we might require
Employment Income	Last recent pay slip
Savings / deposits	Enquiry of the Source of Wealth
Property Sale/Real Estate	Details of the property sold (i.e. address, date of sale, sale value of property sold, parties involved) Copy of contract of sale Invoice from notary Bank statement of the transaction
Sale of shares or other investment	Sale value of shares sold and how they were sold (i.e. name of stock exchange) Transaction receipt/confirmation Shareholder’s certificate Information available in open sources Bank statement of the transaction
Company Sale	Copy of the contract of sale and bank statement showing the proceeds. Signed letter from solicitor/lawyer or regulated accountant incl. specifics of the sale i.e. date, amount, ID of the company. Research in Company Registry Name and Address of Company Total sales price Client’s share participation Nature of business Media coverage (open sources)
Company Profits / Dividends	Copy of latest (audited) financial statements Copy of latest management accounts Board of Directors approval Dividend distribution
Inheritance	Deed of inheritance (Akte van erfrecht) Deed of will
Gift	Deed of gift (schenkingsakte)
Maturity/surrender of life policy	Copy of the policy
Other income sources	Nature of income, amount, date received, from who and why Appropriate supporting documentation
Intercompany payments	A statement outlining the nature of the intercompany payments, along with bank statements of the transfers to substantiate the money trail.
Loans or credit	A statement detailing the composition of the loans or credits, including the loan agreements, and the corresponding transfers to demonstrate the money trail.
Dividends, administration fees etc. from other companies	We would require a copy of the minutes from the shareholders' meeting where the decision to distribute dividends was made, along with the corresponding wire transfer to substantiate the financial transaction.
Cash Injection new Equity	This will involve a document detailing the decision for the capital increase, along with corresponding transfers to substantiate the money trail.
Operating Cash Flow	To assess the operating Cash Flow, we will review the company's public or internal financial statements. If the available cash appears to be insufficient based on the most recent financial statements, we may request a current statement of the company account and possibly some substantial invoices to support significant income.
Golden handshake/Severance Payment	Severance settle letter including details of golden handshake

When providing services to clients in Belgium, please be aware of the following:

• For Belgian clients we do not require a copy of the UBO register, as we have direct access to this national database of the KBO. As part of the KYC assessment, we verify the accuracy of the information in the UBO register by requesting a copy of the company's share register and/or the signed minutes of the last shareholders' meeting, including the attendance list.
• Public financial statements are generally available for most legal entity types in Belgium (e.g., NV, BV). We do not require a copy of the annual accounts for these entities. However, for certain legal entity types where public financial statements are not available (e.g., Comm.V. or VOF), we always request a copy of the full report of the internal annual accounts of the company.
• In cases where a company has been recently incorporated and no public annual accounts are available yet, we require the financial plan at the time of incorporation, as well as a copy of the internal annual accounts (which have not yet been published).

Any questions?

If you have any questions to the above or wish to submit a a set of account opening application, please submit a case via SaxoConnect to Corporate onboarding - new clients.