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EMI Request [UBO source of funds]

VicMcG

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Dec 29, 2022
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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.
 
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.
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.
 
Is it a rule to show the last 6 months?
No, it is not, IMO.
Show the last 12 months for example and explain that the last 6 months he was not working.
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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