1. Purpose

The KYC programme enables Apex to verify the identity of clients, investors, counterparties and their beneficial owners, understand the nature and purpose of the relationship, and assess the associated money-laundering, terrorism-financing, sanctions, tax and reputational risks.

2. When KYC is required

Establishment of any new business relationship.
Occasional transactions at or above the regulatory threshold (EUR 10,000 single transaction or linked).
Any wire transfer subject to Regulation (EU) 2015/847.
When there is a suspicion of money laundering or terrorism financing, regardless of threshold.
When there are doubts about the veracity or adequacy of previously obtained identification data.

3. Required documentation, individuals

Valid government-issued photo ID (passport, EU national ID card or driver's licence).
Proof of residential address dated within the last 3 months (utility bill, bank statement, official correspondence).
Tax identification number and tax residency declaration (CRS self-certification).
Source of funds and, for higher-risk profiles, source of wealth documentation.
PEP self-declaration where applicable.

4. Required documentation, legal entities

Certificate of incorporation or equivalent registry extract (dated within 3 months).
Memorandum and articles of association or equivalent constitutional documents.
Up-to-date shareholding structure and organisational chart.
Identification of all Ultimate Beneficial Owners (UBOs) holding ≥25% ownership or control, with full KYC documents.
Identification of directors, authorised signatories and the appointed compliance contact.
Most recent audited financial statements (or management accounts for entities <2 years old).
Regulatory licences, where applicable.
Board resolution authorising the relationship with Apex.
Tax residency declaration (CRS / FATCA).

5. Required documentation, trusts, foundations and SPVs

Trust deed, foundation charter or SPV constitutive documents.
Identification of settlor, trustees, protector, beneficiaries (or class) and any person exercising effective control.
Source-of-funds and source-of-wealth evidence for the structure and contributors.

6. Verification standards

Documents must be originals, notarised copies or certified by a qualified professional (lawyer, notary, auditor, regulated financial institution). Apex also accepts qualified electronic identification under eIDAS Regulation (EU) 910/2014 and may use accredited remote identity-verification providers using liveness detection and document forensics.

7. Screening

All identified persons and entities are screened at onboarding and continuously thereafter against EU, UN, OFAC and HMT sanctions lists, PEP databases and adverse-media sources. Positive matches are escalated to Compliance for adjudication before approval.

8. Ongoing monitoring and periodic review

Low risk, review every 5 years.
Medium risk, review every 3 years.
High risk, review at least annually.
Trigger-based reviews on material changes (ownership, jurisdiction, activity, adverse news).

9. Refusal and exit

Apex reserves the right to decline onboarding, restrict services or terminate a relationship where KYC requirements cannot be satisfied, where the relationship would expose Apex to unacceptable risk, or where required by law or regulation.

10. Confidentiality and data protection

KYC information is processed in accordance with our Privacy Policy and the GDPR, accessed only on a strict need-to-know basis, and retained for 10 years after the end of the business relationship.

11. Contact

Onboarding enquiries: onboarding@apexeurocapital.com

Know Your Customer (KYC) Policy