Why the file matters more than the jurisdiction
A company registered in the British Virgin Islands, the Cayman Islands or Nevis is not a problem for a regulated payments provider in itself. What the provider has to show, to its regulator and to its own banking partners, is that it knows who owns and controls the company, what the company does and where its money comes from. The documents are how it shows that.
Offshore companies tend to attract more questions for a simple reason: the public registers in many international financial centres disclose less than a UK or Canadian register would. A compliance analyst in Vancouver cannot look up the shareholders of a BVI company online in the way they can look up a company on a fully public register. So the gap is filled with documents issued by the registered agent, signed declarations and certified copies.
If you understand that the provider is trying to rebuild a picture it cannot see directly, the requests make more sense. Each document answers a specific question. When one is missing, the question stays open and the file stalls.
Corporate documents: proving the company exists
The first block of documents establishes that the company was properly formed, still exists and is run by the people who say they run it. Expect to provide:
- Certificate of incorporation (or certificate of registration or formation, depending on the jurisdiction). If the company has changed its name, include the certificate of change of name as well, so the trail from the original name to the current one is unbroken.
- Memorandum and articles of association, or the equivalent constitutional document. For a limited liability company this may be an operating agreement. Providers read these for share classes, restrictions on transfer and signing powers.
- Certificate of good standing, issued by the companies registry, showing the company is up to date with its annual fees and filings. Most providers want one issued within the last three to six months.
- Certificate of incumbency, usually issued by the registered agent, listing directors, shareholders, officers and the registered office. Again, recency matters.
- Register of directors and register of members, if the incumbency certificate does not cover both, or if the provider wants the full history of appointments and transfers.
Where a document is not in English, a certified translation will normally be needed. Our guide to translations and apostilles covers when that applies. For the difference between the two certificates above, see incumbency versus good standing.
Ownership: showing who is behind the company
Every regulated provider has to identify the ultimate beneficial owners: the natural persons who own or control the company, directly or through other entities. The usual threshold for identification is 25 per cent, but many providers apply a lower one for higher-risk activity, and some will want to know about anyone with 10 per cent or more.
For a company owned directly by individuals, the register of members and the incumbency certificate may be enough. For anything layered, you will need:
- A signed ownership chart showing every entity and person from the applicant company up to the individuals at the top, with percentages at each layer. Our guide on how to draw an ownership chart walks through the method.
- Corporate documents for each intermediate entity, usually at least a certificate of incorporation and a register of members or incumbency certificate, so each link in the chain can be verified.
- For trusts in the chain, the trust deed (or a certified extract), details of the trustee, settlor, protector if any, and the beneficiaries or class of beneficiaries.
- Where shares are held by a nominee, a copy of the declaration of trust or nominee agreement identifying the beneficial owner.
The chart and the documents must agree. If the chart says a Cyprus holding company owns 60 per cent and the Cyprus register shows 55 per cent, expect a query until someone explains the difference.
People: directors, owners and signatories
For each beneficial owner, each director and each person who will be authorised to give payment instructions, providers will normally ask for:
- A passport (or national identity card), as a certified copy or verified through an electronic identity check with a live selfie.
- Proof of residential address dated within the last three months, such as a utility bill or bank statement. See our separate note on proof of address requirements for the awkward cases.
- A short profile or CV for beneficial owners, which helps the analyst understand how the person built the wealth that sits behind the company.
- Answers to politically exposed person questions, covering the person and their close family and associates.
Corporate directors are common in offshore structures. If the director is a company, the provider will need that company's corporate documents and the identity of the individuals who act for it. Where the director is a licensed corporate service provider, its licence details may simplify this, although the provider will still decide what it needs.
Authorised signatories are frequently forgotten. A finance manager in Limassol who will release payments needs to be verified, even if they own nothing and sit on no board.
Source of wealth and source of funds
These are two different questions and providers will ask both.
Source of wealth is about the beneficial owner and how this person came to have the assets they have. A founder who sold a logistics business, an heir, a senior executive with a long salary history: each tells a different story and each needs different evidence. Our guide to source of wealth evidence goes into each case.
Source of funds is about the money that will actually move through the account: where the first incoming payment will come from, and what generates the ongoing flows. For a trading company this might be customer receipts; for a holding company, dividends from subsidiaries. See source of funds evidence for worked examples.
Typical documents include audited or management accounts for the company, bank statements showing the initial funding, sale and purchase agreements, dividend resolutions and, for the individuals, tax returns or employment records. Proportionality applies: a modest consulting company will not be asked for the same depth as a structure expecting large monthly flows.
Purpose of the account and expected activity
A provider has to understand why you want the account and what normal use will look like, because that becomes the baseline for monitoring. Be ready to describe:
- What the company does, in plain terms. "Holding company" is a start; "holds 100 per cent of a Polish software subsidiary and receives annual dividends" is what an analyst can use.
- The main counterparties: who pays you, who you pay and where they are based.
- Currencies, expected monthly volume and typical payment size, as ranges.
- Any regulated activity, with copies of licences. An iGaming operator, a CFD broker or a defence supplier will need to evidence its authorisation or export permissions.
- Supporting contracts or invoices for the first expected flows.
Example: a BVI holding company expects to pay a supplier in Malta around EUR 40,000 a month for software development, funded by royalty income from a licensee in Germany. Giving the analyst the services agreement with the Maltese supplier and the licence agreement with the German licensee answers most follow-up questions before they are asked.
The checklist at a glance
The table below summarises a typical request for a single-layer offshore company. Requirements vary by provider and by risk, so treat it as a starting point.
| Document | Who issues it | Typical recency | Format |
|---|---|---|---|
| Certificate of incorporation | Companies registry | Any date | Certified copy |
| Memorandum and articles | Company or registered agent | Current version | Certified copy |
| Certificate of good standing | Companies registry | Usually within 3 to 6 months | Original or certified copy |
| Certificate of incumbency | Registered agent | Usually within 3 to 6 months | Original or certified copy |
| Register of members and directors | Registered agent | Recent extract | Certified copy |
| Ownership chart | Company | Current, signed and dated | Signed PDF |
| Passport for each owner, director and signatory | Issuing state | Unexpired | Certified copy or e-verification |
| Proof of address for each individual | Utility, bank or tax authority | Within 3 months | Certified copy or original PDF |
| Source of wealth evidence | Various | Depends on event | Copies, certified if requested |
| Financial statements or bank statements | Company or its bank | Most recent period | |
| Licences and key contracts | Regulator or counterparties | Current |
What usually slows an application down
From the provider's side, the same issues come up again and again:
- Stale certificates. A good standing certificate from eighteen months ago proves the company existed then, not now. Order fresh ones before you apply.
- Charts that do not match the registers. Old transfers that were never updated with the registered agent are a frequent cause.
- Missing middle layers. Applicants supply documents for the operating company and the individuals, but nothing for the Seychelles or Cyprus holding company in between.
- Vague purpose. "General trading" with no named counterparties invites a long list of follow-up questions.
- Certification that does not meet the provider's standard, such as a copy stamped by a friend with no stated profession. Our note on certified copies explains the usual expectations.
- Funding that cannot be traced. If the first deposit comes from an account in a third party's name, expect to explain why.
None of these means the application will fail. They mean the analyst has to stop, write to you and wait. Each round trip adds days.
How to prepare a clean submission
A few habits make a real difference:
- Ask your registered agent for a full pack at once: good standing, incumbency, registers and a certified set of constitutional documents, all dated the same week.
- Draw the chart first, then gather documents for every box on it. If you cannot find a document for a box, you have found your gap early.
- Write a one-page cover note explaining the structure, why it exists, what the account is for and where the money comes from. Analysts read hundreds of files; a clear narrative saves time on both sides.
- Name files consistently, for example "02 Certificate of good standing BVI 2026-09". It sounds trivial, but it reduces the chance something is overlooked.
- Keep one person as the point of contact who understands the structure and can answer questions without forwarding them to three advisers.
- Diarise expiry dates for passports and certificates, because the same documents will be requested again at periodic review.
If the structure has unusual features, such as a protector with wide powers, bearer-type instruments historically, or a recent change of ownership, say so in the cover note. Disclosed complexity is far easier to deal with than complexity the analyst discovers later.
Before you act
This guide is general information about common onboarding requirements. It is not legal or tax advice, and individual providers set their own requirements based on their regulatory obligations and risk appetite. Your corporate service provider and legal advisers are the right people to confirm what your structure can produce.
If you are preparing to open an account with CCYFX, our onboarding checklist builder lists the documents commonly requested for different entity types, and the how it works page explains each stage of the process.
