CDD information

As a financial services provider, we are subject to European Anti-Money Laundering Regulations, or AML Directives and Sanctions Legislation. At SimpledCard, we closely monitor developments in these laws and regulations to keep our product constantly ‘compliant’.

How does regulation work?

These European laws and regulations are transposed into national legislation. In the Netherlands, the AML directive has been translated into the Wwft (Money Laundering and Terrorist Financing (Prevention) Act). This national and European legislation requires us to conduct customer due diligence. To a large extent, an institution is allowed to shape the degree of client screening in a risk-based manner. Together with our partners, we determine this risk appetite. In addition, local regulators provide further guidance on how laws and regulations should be interpreted and how such measures can be implemented.

The financial service provider's own responsibility as gatekeeper is paramount. We feel responsible for protecting society from financial crime and we have an important task to combat issues such as money laundering or terrorist financing. More information on the Anti-Money Laundering Regulations and the Wwft can be found at this link.

We are therefore required by law to know with whom we do business. To identify who the natural persons behind an entity are, we request certain documents.

Who are the natural persons behind an entity?

✓ Directors

✓ Ultimately interested parties (UBOs)

Explanatory note UBO

The ultimate stakeholders of an organisation are the individuals who ultimately own or control an organisation. Directly or indirectly. These are:

  • People who are shareholders for more than 25%;
  • People who have more than 25% voting rights;
  • People who have more than 25% economic interest;
  • People who have actual control based on other means;
  • If a person is a director, and in addition has no other (direct or indirect) interest in the organisation, that person is not a UBO based on actual control.

Are none of these interests applicable? Then the directors are the UBOs. These are the board members who are or should be registered with the Chamber of Commerce. This is called pseudo-UBO.

What kind of documents do we request to verify the identity of directors and UBOs and to comply with our other legal obligations?

ID copies

A copy of a valid passport, driving licence or national identity card. A copy of proof of identity is only valid if:

  • it is fully visible; both sides are required if it is an ID;
  • it is in colour;
  • the photo is clearly visible;
  • the document number is legible.

✓ Directors

From at least 2 directors when there are several. This should include the identity documents of the directors who signed the contract.

Organisation chart external structure

An organisation chart is requested because we are required to understand the ownership and control structure with percentages of shareholding visible between the entities of the group to which a client belongs. We need to be able to determine whether the documents provided are authentic. We therefore require the document to be signed by the registered signatories.

Financial statements

You will be asked to provide your most recent financial statements, as filed with the Chamber of Commerce, as we, as gatekeepers, are obliged to investigate the source of your business assets.

Bank statement

Only a business bank account is allowed. This must be the same account from which the Card Management System principal balance will be replenished.

The bank statement should be an official document from the banking environment, not older than 3 months, with good legibility:

  • the bank name;
  • company account name;
  • IBAN number.