AML compliance for a new company is a control file, not a one-off form. A new company should prepare the ownership and operating story before its first bank, EMI, investor, or regulated-counterparty application. The file is easier to review when it is consistent from incorporation papers to expected payment flows.
What should a new company prepare before onboarding?
Start with incorporation documents, a clear ownership chart, verified identity records for controllers, and a plain-language explanation of products, customers, geography, and expected receipts and payments. Keep every document current and internally consistent.
What does customer due diligence actually cover?
CDD is a practical evidence process. It connects the legal entity to the people who control it and to the commercial activity it says it will conduct. UK Money Laundering Regulations, regulation 28 sets out a useful statutory baseline: identify and verify the customer, establish beneficial ownership where relevant, understand the relationship, and monitor it. Exact obligations depend on the country and the firm reviewing the file.
- Certificate of incorporation, constitutional documents, and current registry extract.
- Ownership chart showing direct and indirect control.
- Identity and address evidence for relevant owners and directors.
- Short business, customer, supplier, and expected-payment narrative.
Why are company registers and KYC reviews separate?
A public or government register is an important reference point, yet it is only one input in a risk-based onboarding decision. A company ownership register and a financial institution's onboarding review serve different purposes. For a UK example, GOV.UK PSC guidance explains that companies must identify and report people with significant control. That disclosure does not replace an institution's own risk assessment.
How long should records be kept and refreshed?
Use the applicable local retention period and the reviewer’s policy, then build a routine around real changes rather than a calendar-only exercise. Retain dated copies, keep a simple change log, and make the payment-flow narrative match the contracts and invoices actually used. A changing shareholder, new market, or unfamiliar source of funds should trigger a file refresh, not a retrospective scramble.
Does a filing exemption remove onboarding work?
No. A filing exemption can change a government reporting duty, while onboarding controls remain a commercial and regulatory decision for each provider. In the United States, FinCEN beneficial ownership information guidance describes the current BOI-reporting position. That government filing position must not be confused with private bank or EMI KYC, which can still request beneficial-owner and source-of-funds evidence.
Frequently asked questions
Is enhanced due diligence an allegation of wrongdoing?
No. It is a higher-evidence process used where the risk profile calls for it.
Can a bank rely only on a company registry extract?
Usually no. It will commonly ask for ownership, activity, and payment-flow evidence as well.
When should the file be updated?
Update it when ownership, directors, activity, markets, counterparties, or the source-of-funds story materially changes.
For a jurisdiction-specific implementation plan, review Corpenza audit and compliance support, company-formation support, or contact Corpenza.
General information only, not legal, tax, or compliance advice. Rules and provider requirements change.
