EMI Request [UBO source of funds]

[VicMcG]

Hey guys,

I need some assistance regarding onboarding with a UK EMI.

I have a client setting up a BG Crypto Exchange and onboarding is nearly completed but the EMI is looking for source of funds of the UBO.

This operation is a startup so we could not involve any third parties/entities and it was disclosed that the UBO is funding the operating via his savings. Based on his CV, the UBO's last employment was in mid 2022 and his last 6 month bank statements is not showing any transactions - so explaining how the business was set up is a problem.

Any ideas how we can work around a situation like this to finalize the onboarding?

Thank you.

 

[CyprusLawyer101]

How were set up costs actually paid?

 

[VicMcG]

CyprusLawyer101 said:
How were set up costs actually paid?
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It was paid for in crypto by my client to the firm offering these services. (ready made company + UBO/Director services)

 

[AndyAresa]

VicMcG said:
+ UBO/Director services)
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do you mean the firm also offers and actually provides UBO services?

 

[JohnnyDoe]

VicMcG said:
Any ideas how we can work around a situation like this to finalize the onboarding?
Click to expand...

Adjust the CV, use photoshop, or allocate a $50 budget to employ someone who can use it.

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[MiltonStone]

Very easy to photoshop something or you ask your provider of the setup to help you out. If they are good in what they are doing, they can help you.

 

[CyprusLawyer101]

VicMcG said:
It was paid for in crypto by my client to the firm offering these services. (ready made company + UBO/Director services)
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So this is obviously a crypto friendly EMI so why dont you just tell them you paid in crypto?

 

[newguyhere]

VicMcG said:
Hey guys,

I need some assistance regarding onboarding with a UK EMI.

I have a client setting up a BG Crypto Exchange and onboarding is nearly completed but the EMI is looking for source of funds of the UBO.

This operation is a startup so we could not involve any third parties/entities and it was disclosed that the UBO is funding the operating via his savings. Based on his CV, the UBO's last employment was in mid 2022 and his last 6 month bank statements is not showing any transactions - so explaining how the business was set up is a problem.

Any ideas how we can work around a situation like this to finalize the onboarding?

Thank you.
Click to expand...

Is it a rule to show the last 6 months? Show the last 12 months for example and explain that the last 6 months he was not working.

 

[Forester]

newguyhere said:
Is it a rule to show the last 6 months?
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No, it is not, IMO.

newguyhere said:
Show the last 12 months for example and explain that the last 6 months he was not working.
Click to expand...

This seems to be really easy but it does not solve the problem / amswers the question how the company was set-up, see above.

Just to remark, if the clients reveals that the company set-up was paid in crypto, it is fully expectable that the EMI will wonder about how this crypto was earned.

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