Not applicable for this jurisdiction.

Branch

Financial institutions; professionals working within the financial sector, bullion and gambling sectors; and other regulated entities (ie, reporting entities) are required to satisfy their respective KYC obligations. Legal service providers may have their own internal KYC requirements.

Proprietary company

Financial institutions; professionals working within the financial sector, bullion and gambling sectors; and other regulated entities (ie, reporting entities) are required to satisfy their respective KYC obligations. Legal service providers may have their own internal KYC requirements.

Public company

Financial institutions; professionals working within the financial sector, bullion and gambling sectors; and other regulated entities (ie, reporting entities) are required to satisfy their respective KYC obligations. Legal service providers may have their own internal KYC requirements.

Stock corporation (AG)

The stock corporation is not subject to any KYC rules.

Limited liability company (GmbH) and Flexible Company (FlexKapG)

The company is not subject to any KYC rules.

With Limited Liability (WLL)

Not required by law; however, may be required if stated in the company's internal regulations. If the company exercises CBB regulated activities, then it must follow the guidelines set by the CBB to prevent money laundering.

Closed Shareholding Company (BSC(c))

Not required by law; however, may be required if stated in the company's internal regulations. If the company  exercises CBB regulated activities, then it must follow the guidelines set by the CBB to prevent money laundering.

Foreign Branch (Branch)

Not required by law; however, may be required if stated in the company's internal regulations. If the company is exercising CBB regulated activities, then it must follow the guidelines set by the CBB to prevent money laundering.

Public limited company (société anonyme/naamloze vennootschap)

Know-your-client requirement ( ie, anti-money laundering): notary public, bank and law firm.

A company must report and confirm its ultimate beneficial owners once a year to the Belgian administration, including the full group structure up until the ultimate beneficial owner(s). Any change in the ultimate beneficial owners must be reported within 1 month.

Limited company (société à responsabilité limitée/besloten vennootschap)

Know-your-client requirement ( ie, anti-money laundering): notary public, bank and law firm.

A company must report and confirm its ultimate beneficial owners once a year to the Belgian administration, including the full group structure up until the ultimate beneficial owner(s). Any change in the ultimate beneficial owners must be reported within 1 month.

Belgian branch office of a foreign company

It is possible that the Belgian bank has certain know-your-client requirements in view of opening a Belgian bank account. A Belgian branch does not need to register its ultimate beneficial owners in the Belgian UBO register.

Limited liability company (Sociedade Limitada)

During the procedure of opening the company's bank account, the documents required may vary from bank to bank.

Corporation (Sociedade Anônima)

During the procedure of opening the corporation's bank account, the documents required may vary from bank to bank.

Corporate subsidiary

Typically required by law societies in various Canadian provinces and territories.

Required by banks, AGFs and insurance companies.

In connection with the information reporting to the  MOFCOM, information about an ultimate actual controller of the company as well as that of all the investors must be disclosed to MOFCOM. The disclosed information should generally allow the MOFCOM to trace the investment all the way up to either natural person, publicly listed company, foreign government (including government fund) or international organization owning or controlling 50 percent or more of the interest of a foreign investor. Practice of the local counterpart of the MOFCOM varies, but it may be possible to list only the largest shareholder, and to group multiple smaller shareholders together without specifying their names.

Effective from November 1, 2024, subject to applicable exceptions, newly established LLCs are required to record the beneficial owner information with the central bank of China, ie, the People’s Bank of China via the AMR online system, and existing LLCs will be required to file a make-up registration to record the same by November 1, 2025.  The beneficial owner shall be traced up to the natural person who ultimately owns or actually controls the LLC or enjoys the ultimate beneficial ownership of the LLC.

Banks may have separate and different "know your client" or anti-money laundering requirements.

Depending on the company's object and line of business, it may or may not be obligated to have a Know-Your-Client policy.

Czech "know your client" requirements are based on European provisions. Most applicable law is the Anti-Money Laundering Act.

Thereunder, transactions are subject to different identification measurements and reporting duties, with penalties resulting from non-compliance. These vary from simple proof of identification (for individuals) – respectively a physical/electronic record of the company – to simple or enhanced due diligences depending on the risk. For instance, politically exposed persons (PEPs) are always subject to enhanced due diligences.

Limited liability company (Kapitalselskab)

There are no general "KYC" requirements applicable to all companies in Denmark.

However, several specific businesses such as banking, law firms, accountants and real estate agencies are subject to the Danish Money Laundering Act, which contains certain "know your client" requirements. Business is required to provide sufficient and correct information upon request from the relevant authorities.

Not applicable for this jurisdiction.

Osakeyhtiö (Oy)

In case the company intends to make transactions, investments, open a bank account or similar, certain KYC requirements apply pursuant to anti-money laundering legislation.

Société par actions simplifiée (SAS)

Not required from a corporate law standpoint. However, at the time of the opening of a bank account in the name of the company, the bank will ask for KYC documents.

Société à responsabilité limitée (SARL)

Not required from a corporate law standpoint. However, at the time of the opening of a bank account in the name of the company, the bank will ask for KYC documents.

Société anonyme (SA)

Not required from a corporate law standpoint. However, at the time of the opening of a bank account in the name of the company, the bank will ask for KYC documents.

GmbH – limited liability company

The German "Know Your Client" requirements are based on the European provisions.

Most common applicable law is the Anti-Money Laundering Act (Geldwäschegesetz), pursuant to which transactions are subject to different identification and reporting requirements, with penalties resulting from non-compliance. These vary from simple proof of identification (for individuals) or a physical/electronic record of the company, to simple or enhanced due diligence, depending on the risk. For example, Politically Exposed Persons (PEPs) are always subject to an enhanced due diligence process.

The reporting is made to the Criminal Investigation Department of the relevant state and to the central Criminal Investigation Department of Germany (Central Division for Suspicious Activity Reports (Financial Intelligence Unit FIU)).

"KNOW YOUR CLIENT" requirements are not mandatory for any legal person to cooperate with a law firm.

"KNOW YOUR CLIENT" requirements constitute a mandatory process relating to banking transactions (i.e. opening of a banking account).

Greek legislation stipulates the mandatory registration in the Central Register of UBO of companies based in Greece or conducting business activity taxed in Greece.

Limited private companies

Professional service providers complete customer due diligence according to guidelines issued by the Companies Registry on compliance of anti-money laundering and counter-terrorist financing requirements for Trust or Company Service Providers.

Service providers (eg, inter alia, law firms, credit institutions, financial service providers, auditor companies, funds and tax advisers) must verify the identity of their clients for anti-money laundering purposes before entering into an engagement. Service providers must record the identification data of a client (in the case of natural persons: name and surname, name at birth, nationality, date and place of birth, mother's birth name, home address, number and type of identification document; in the case of legal entities and unincorporated organizations: name, abbreviated name, registered office, main activities, name and position of authorized representatives, identification data of the agent for service of process, registration number and tax number).

For the purposes of identification and verification procedures, service providers must require the presentation of various documents (in the case of natural persons: an official document suitable for identification purposes and official address card for Hungarian citizens, and passport or personal identification document for foreign nationals; in case of legal entities and unincorporated organizations: personal identification documents of a natural person acting on behalf of a legal entity or unincorporated organization, documentary evidence of registration or that an application for registration has been submitted, and a constitutional document if an application for registration has not yet been submitted).

If the client is a natural person, it is required to provide a written statement as to whether the person is acting in the name or on behalf of a beneficial owner. The statement must indicate the following data of the ultimate beneficial owner:

• Name at birth;
• Nationality;
• Date and place of birth and;
• Home address.

The service provider must additionally request a statement declaring whether the beneficial owner is a politically exposed person.

If a client is a legal entity or unincorporated organization, it is required to provide a written statement identifying its ultimate beneficial owner; the statement must indicate the following data of the ultimate beneficial owner:

• Name and surname;
• Name at birth;
• Nationality;
• Date and place of birth;
• Home address and;
• The nature and extent of ownership interest.

The service provider must additionally request a statement declaring whether the beneficial owner is a politically exposed person.

Private limited company

Know-your-client requirements are mandatory for incorporation as well as for the opening of a bank account. Significant beneficial owner filing requirements apply to all shareholders who hold more than 10 percent or more in the company.

Limited liability company

Banks and financial service institutions in Indonesia are required to apply certain know your client principles. Indonesian companies, as well as notaries, are required to identify, verify and report the ultimate beneficial owner to the government. If necessary, a government institution may audit a company to identify and verify its beneficial owner.

Private company limited by shares (LTD)

Typical KYC information required by, for example, banks and professional services firms is as follows:

• Proof of incorporation/registration
• Up-to-date list of directors
• Identification of the ultimate beneficial owners
• Personal identification of at least 1 director (ie, copies of a recent utility bill and passport or driver's license) and
• Disclosure of any politically exposed persons

KYC information does not need to be submitted for the incorporation of the company itself.

External company

Typical KYC information required in respect of the foreign company by, for example, banks and professional service firms is as follows:

• Proof of incorporation / registration
• Up-to-date list of directors (if any)
• Identification of the ultimate beneficial owners

• Personal identification of at least 1 director (ie, copies of a recent utility bill and passport or driver's license) and

• Disclosure of any politically exposed persons

KYC information does not need to be submitted for registration of the branch.

Company

To open a tax file, the company will need to have bank account and the bank will have the “know your client” requirements under Israeli anti money laundering laws.

Branch / representative office

To open a tax file, the company will need to have bank account and the bank will have the “know your client” requirements under Israeli anti money laundering laws.

Società a responsabilità limitata (S.r.l.) and Società per azioni (S.p.A.) 

Not applicable for this jurisdiction.

For the sake of completeness, please note that on October 9, 2023, the UBO (ultimate beneficial owner) register became fully effective and operational in Italy, through the Ministerial Decree no. 236/2023. Consequently, all the Italian entities had to notice their UBO(s) with the Italian Companies’ Register, pursuant to the following criteria set out by Legislative Decree no. 231/2007 (the “AML Decree”):

• the primary criterion for identification of UBO(s) is – pursuant to article 20.2 of the AML Decree - the following: “the natural person(s) who (directly or indirectly) own(s) more than 25 percent of the corporate capital”;
• where identification of UBO(s) is not possible based on the above criterion, article 20.3 of the AML Decree states that UBO(s) is the person/entity having, alternatively: (i) control of the majority of votes in the shareholders’ meeting of the company; or (ii) control of sufficient votes to exercise a dominant influence in the shareholders’ meeting of the company; or (iii) presence of specific contractual liens allowing the exercise of a dominant influence over the company;
• where identification of UBO(s) is not possible based on the above criteria, article 20.5 of the AML Decree provides an “ultimate” residual criterion, identifying UBO(s) as the “natural person(s) – pursuant to the organizational setup applicable to the company - holding legal representation authority, management authority or authority of direction of the company”.

Please note that following the orders no. 08245/2024 and no. 08248/2024, issued by the Italian Council of State (Consiglio di Stato), the obligation to notice the company’s UBO(s) with the Italian Companies’ Register is currently suspended.

Registered branch

There is no need to register information regarding the controller of the company. Only specific business operators, such as financial institutions, are required to conduct customer due diligence.

Kabushiki-Kaisha (KK)

There is no need to register information regarding the controller of the company. Only specific business operators, such as financial institutions, are required to conduct customer due diligence.

Godo-Kaisha (GK)

There is no need to register information regarding the controller of the company. Only specific business operators, such as financial institutions, are required to conduct customer due diligence.

Private limited liability company (Société à responsabilité limitée or S.à r.l.)

Lawyers, banks and professionals of the financial sector, including domiciliation companies (corporate services providers), as well as notaries, are subject to KYC obligations.

The Luxembourg law setting-up a register of beneficial owners, implementing the EU Directive on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, lays down the following main obligations:

1. Obtaining and maintaining up-to-date information concerning beneficial owners of any Luxembourg entities at their registered office

2. Filing such information in a new, specially created, register in Luxembourg and

3. Providing information on beneficial owners to (i) national authorities (upon simple request) and (ii) certain professional organizations and professionals of the financial sector (upon grounded request).

The notion of "beneficial owner" is defined by the Luxembourg law of 12 November 2004 on the fight against money laundering and terrorist financing, as amended from time to time. In a nutshell, it refers to any individual ultimately who either holds, directly or indirectly, more than 25 percent of the company's capital or voting rights, or exercises, by any other means, a control over the management or executive bodies of the company or over the general meeting of its shareholders.

In case it can be confirmed that no natural person owns, holds or controls, directly or indirectly, at least 25 percent of the relevant entity and, therefore, no person meets the requirements to be identified as beneficial owner, the name (and details) of the senior managing official(s) (dirigeant(s) principal/principaux) should be communicated to, and filed with, the Luxembourg beneficial owners register.

While no definition of the term "senior managing official(s)" has been provided by the Luxembourg law, the Circular LBR 19/02 of 18 March 2019 issued by the Luxembourg business registers (which is not a source of binding law, but is limited to provide a certain guidance on the interpretation of law) provides that the term of "senior managing official" refers to the entire management body of a "company".

Criminal sanctions amounting to fines ranging from EUR 1 250 to EUR 1 250 000 may be applied to entities within the scope and on the beneficial owners in case of non-compliance.

Public limited liability company (Société anonyme or S.A.)

The same rules as the ones set out above apply to S.A.

Special limited partnership (Société en commandite spéciale or SCSp)

The same rules as the ones set out above apply to SCSp.

Electronic Know-Your-Customer (e-KYC) is mandatory in the financial sector (banks and financial institutions) to verify the identities and suitability of customers as well as the risks involved in maintaining a business relationship with them. The policy document regarding the guidelines for e-KYC is published by the Central Bank of Malaysia (BNM).

Know your client requirements (ie, anti-money laundering) apply to banks, law practitioners and law firms, management companies and other financial institutions in accordance with the Financial Intelligence and Anti-Money Laundering Act 2002 of Mauritius.

S.A. de C.V.

Required by Notary Public for incorporation purposes: filing of a questionnaire, provide proof of legal existence and powers of attorney granted by the shareholders, if applicable.

S. de R.L. de C.V.

Required by Notary Public for formation purposes: filing of a questionnaire, provide proof of legal existence and powers of attorney granted by the partners, if applicable.

S.A.P.I. de C.V.

Required by Notary Public for incorporation purposes: filing of a questionnaire, provide proof of legal existence and powers of attorney granted by the shareholders, if applicable.

Branch office

Dutch civil law notaries and trust companies each have their own KYC requirements. Generally, clients are required to disclose the identities of ultimate beneficial owners (natural persons directly or indirectly holding more than 25 percent of the shares or the voting rights) and provide documentation, such as notarized and apostilled passport copies, of individuals involved with the branch office as director or proxy holder.

B.V. (private company with limited liability)

Dutch civil law notaries and trust companies each have their own KYC requirements. Generally, clients are required to disclose the identities of ultimate beneficial owners (natural persons directly or indirectly holding more than 25 percent of the shares or the voting rights) and provide documentation, such as notarized and apostilled passport copies, of individuals involved with the BV as director or (representative of) shareholder.

Co-operative U.A.

Dutch civil law notaries and trust companies each have their own KYC requirements. Generally, clients are required to disclose the identities of ultimate beneficial owners (natural persons directly or indirectly holding more than 25 percent of the interests in the co-operative or the voting rights) and provide documentation, such as  notarized and apostilled passport copies, of individuals involved with the co-operative as board member or (representative of) member.

C.V. (a limited partnership)

Dutch lawyers, civil law notaries and trust companies each have their own KYC requirements. Generally, clients are required to disclose the identities of ultimate beneficial owners (natural persons directly or indirectly holding more than 25 percent of the interests in the CV or the voting rights) and provide documentation, such as notarized and apostilled passport copies, of individuals involved with the CV as a partner (or management committee member).

Limited liability company

Financial institutions, professionals working within the financial sector, bullion and gambling sectors as well as other regulated entities (ie, reporting entities) are required to satisfy their respective KYC obligations. Legal service providers are now subject to the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT) due diligence compliance requirements, in addition to their own internal KYC requirements. In general, this requires identity verification of the ultimate beneficial owners of an entity but can vary depending on the nature of the business conducted by the entity.

Branch

Financial institutions, professionals working within the financial sector, bullion and gambling sectors as well as other regulated entities (ie, reporting entities) are required to satisfy their respective KYC obligations. Legal service providers are now subject to AML/CFT due diligence compliance requirements in addition to their own internal KYC requirements.

Please note that there are sector specific KYC requirements applicable to each company based on their assessed value. However, the general KYC requirements include the following:

• Evidence of registration in the Country of Incorporation (for corporates) Certificate of incorporation

• Relevant resolution approving the transaction

• Passport photograph

• Valid form of identification

• Name, place and date of birth Gender

• Address and proof of residency

• Occupation

The requirements will depend on the bank in question.

Required by banks and insurance companies.

In compliance with the Anti-Money Laundering Act of 2001, a bank is covered by the "Know-Your-Customer" Rule of the BSP and is obligated to implement procedures that would properly identify/verify the existence of its clients. As such, the foreign company must comply with the bank's procedure/requirements to be able to open an account/remit the necessary funds to set up its business in the Philippines.

The Polish "know your client" requirements, applicable to all organizational business forms, are mostly contained in the Act on Combating Money Laundering and the Financing of Terrorism. The requirements contained in this act are based on the relevant EU laws that set forth a host of registry, identification and reporting duties on companies, partnerships and foreign entities conducting business in Poland through branches and representative offices. There are some additional, local requirements under guidance of the Ministry of Finance on the due diligence on verification of contracting parties.

As of July 2020, all partnerships (except of professional partnerships) and all commercial companies (except of public joint-stock companies) are obliged to file information about their Ultimate Beneficiary Owner (the “UBO”) to the public register called: Central Register of Beneficiary Owners (Polish: Centralny Rejestr Beneficjentów Rzeczywistych). Filling can be done only in an electronic form with a qualified electronic signature issued by one of the Polish providers or with a trusted signature (by using state platform called ePUAP) of individual(s) authorized to represent a company.

Information on the UBO have to be reported within 7 days. Failure to comply with the abovementioned requirements may result in a fine up to EUR1 million.

The beneficial owner(s) of a company must be disclosed upon:

1. Incorporation
2. Submission of the yearly accounts (IES) and
3. Occurrence of any changes to the information previously

Law firms and other services providers (eg, audit firms) are subject to KYC proceedings, depending on the type of services provided. For instance, for law firms, KYC proceedings are required if the firm is receiving and paying any amounts on behalf of the client.

Corporations

Not applicable for this jurisdiction.

Limited Liability Companies

Not applicable for this jurisdiction.

Depending on the sector of the company activities, specific requirements may apply.

Joint-stock company (public and non-public)

Typically not required, though legal service providers may have their own KYC documents to be completed.

Limited liability company

Typically not required, though legal service providers may have their own KYC documents to be completed.

Limited liability company

Not required by law.

Limited liability company

Legal service providers are required to complete stringent KYC procedures which includes identifying ultimate beneficial individual owners of shares and verifying the residential addresses of directors.

A bank’s KYC requirements are guided by the Financial Intelligence Centre Act 38 of 2001 and other applicable anti-money laundering and counter-terrorism legislation. These requirements differ amongst the banks as the information required by the bank is subject to the bank's internal policy. At minimum, the bank will request the proof of identity of a company's directors, confirmation of its incorporation details, proof of its registered address, details of its trading name, proof of its operating address (if different from the registered address), the contact details of the company as well as the company's tax and value-added-tax registration numbers (if applicable). In all cases, originals or certified copies of the original documents must be submitted.

Joint-stock company (Jusik Hoesa)

The bank may require information regarding the member or the shareholder information of the shareholder and supporting documents for its KYC process and Korean banking law compliance purposes (eg, shareholders registry of the shareholder). The information required by the bank is subject to the bank's internal policy and may differ among banks.

Limited company (Yuhan Hoesa)

The bank may require information regarding the member or the shareholder information of the member and supporting documents for its KYC process and Korean banking law compliance purposes (eg, shareholders registry of the member). The information required by the bank is subject to the bank's internal policy and may differ among banks.

Branch (Sucursal)

An ultimate beneficial ownership declaration, in which any ultimate beneficiary owning (directly or indirectly) more than 25 percent of the company must be identified, is required.

Limited liability company (Sociedad Limitada)

An ultimate beneficial ownership declaration, in which any ultimate beneficiary owning (directly or indirectly) more than 25 percent of the company must be identified, is required.

Joint-stock company (Sociedad Anónima)

An ultimate beneficial ownership declaration, in which any ultimate beneficiary owning (directly or indirectly) more than 25 percent of the company must be identified, is required.

In case the client plans to make transactions, investments or similar, certain KYC requirements apply.

Stock corporation

No general KYC requirements except for financial intermediaries and dealers, as defined in the Swiss Anti-Money Laundering Act.

However, reporting requirements regarding the identity of the owner of bearer shares and regarding the ultimate beneficial owner of shareholders holding more than 25 percent of the voting rights or capital in a stock corporation may apply to unlisted stock corporations.

Generally not required. Entities in the financial sector will typically impose their own KYC requirements in accordance with Taiwan Anti-Money Laundering Act (AMLA).

May be required if a company operates a regulated business such as commercial banks or other types of financial institutions.

Not applicable for this jurisdiction, apart from certain industries (eg, banking, insurance.)

Limited Liability Company

Although the law generally imposes such obligation only for certain types of entities (eg, banks, insurance companies, exchanges, legal services providers), it is a common approach to perform a limited KYC procedure in order to protect the company from potential risks.

Private Joint-Stock Company

Although the law generally imposes such obligation only for certain types of entities (eg, banks, insurance companies, exchanges and legal services providers), it is a common approach to perform a KYC procedure in order to protect the company from potential risks.

LLC

Strict requirements for banks, money exchange houses, finance companies and financial institutions operating in the UAE to follow “know your customer” guidelines to prevent money laundering. In accordance with the UAE Central Bank regulations, the banks are required to trace the details of the ultimate beneficial shareholder owning 25 percent or more of the shares in the company. The relevant only requires details of the immediate shareholders of the company and will not request for details of the ultimate beneficial shareholders.

Branch

Same as the LLC.

FZ-LLC

Strict requirements for banks, money exchange houses, finance companies and financial institutions operating in the UAE to follow “know your customer” guidelines to prevent money laundering. Most free zones require compliance with this requirement and want to trace details of the ultimate beneficial shareholder owning 5 percent or more of the shares in the FZ-LLC.

FZ-Branch

Same as FZ-LLC.

Dual Licensee Branch

Same as branch.

Private limited company

Generally not required. Firms in the financial or legal sector and third parties which provide company secretarial services will typically impose their own KYC procedures.

Limited liability partnership (LLP)

Generally not required. Firms in the financial or legal sector and third parties which provide company secretarial services typically impose their own KYC procedures.

Registered UK establishment

Generally not required. Firms in the financial or legal sector will typically impose their own KYC procedures.

US law firms are subject to specific "know your client" requirements that require the firm to apply identity verification rules.

The Corporate Transparency Act

The Corporate Transparency Act (CTA) is a U.S. law that requires certain businesses to file a “Beneficial Ownership Information” (BOI) report with the Department of Treasury's Financial Crimes Enforcement Network (FinCEN), disclosing ownership information.  The CTA is designed to combat money laundering, terrorist financing, and other illicit activities by preventing individuals from hiding behind anonymous business entities.  The CTA has come under challenge in the U.S. courts, where a nationwide injunction was issued in late 2024.  The outcome of the court injunction and the validity of the CTA is unclear the time of this summary.

Generally, none, except for some special business activities, such as those taken up by banks.