KYC Requirements by Country

What KYC is and why it matters for company formation

KYC — Know Your Customer — is the process by which financial institutions and regulated entities verify the identity of their clients. For businesses, this includes verifying:

1. 1The identity of the company (legal entity)
2. 2The identity of the beneficial owners (usually anyone owning 25%+ of shares)
3. 3The identity of the directors
4. 4The source of funds (where the money in the company comes from)
5. 5The nature of the business (what the company does and where)

KYC requirements are driven by:

• National AML (Anti-Money Laundering) legislation
• FATF (Financial Action Task Force) Recommendations — the global AML standard-setter
• EU AML Directives (for EU member states)
• Bilateral and multilateral agreements between countries

For company formation, KYC requirements mean: the documents you need to gather not just for incorporation, but for banking, payment processors, and regulated service providers.

Standard KYC document requirements

Regardless of jurisdiction, you should expect to provide the following for each director and beneficial owner (25%+):

For individuals:

• Valid government-issued photo ID (passport strongly preferred — national ID cards accepted in some cases)
• Proof of residential address (utility bill, bank statement, or government document issued within the last 3 months, showing name and address)
• For PEPs (politically exposed persons): enhanced due diligence including source of wealth documentation

For the company:

• Certificate of Incorporation
• Memorandum and Articles of Association / Operating Agreement / Bylaws
• Register of Directors
• Register of Members / Shareholders (showing beneficial ownership)
• Certificate of Good Standing (for existing companies — issued by the company registry confirming the company is in good standing)
• For complex structures: documentation of each entity in the ownership chain, up to and including the ultimate beneficial owner (UBO)

KYC requirements and beneficial ownership registers by jurisdiction

United Kingdom

Beneficial ownership register: Fully public. The PSC (Persons with Significant Control) Register at Companies House is publicly accessible. Anyone owning or controlling 25%+ of shares or voting rights must be registered.

Companies House verification: From 2024, Companies House has been implementing enhanced verification of directors and PSCs — identity verification required for all new director and PSC registrations.

AML legislation: The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended) implement the EU 5th AML Directive.

For banking: All UK banks must conduct KYC. Enhanced due diligence applies to politically exposed persons, non-EEA beneficial owners (in some cases), and high-risk business types.

European Union

Beneficial ownership register: Required in all EU member states under the 4th and 5th AML Directives. Registers vary in public accessibility by country — some are fully public, others require a demonstrable legitimate interest. The EU Court of Justice ruled in November 2022 that fully public access to beneficial ownership registers violates the right to privacy (EU Charter); member states are implementing access restrictions.

AML legislation: EU AML Directives, implemented via national law. The forthcoming EU AML Regulation (expected to come into force 2025–2027) will harmonise AML rules across the EU.

Specific country notes:

• Germany: Transparenzregister — beneficial owners must register. Publicly accessible for most entries.
• Netherlands: UBO Register — required; public access (subject to CJEU ruling implementation)
• Ireland: Central Register of Beneficial Ownership — not fully public; accessible to law enforcement and competent authorities
• Estonia: e-Business Register includes shareholder information; largely publicly accessible

United States

Beneficial ownership: Corporate Transparency Act (CTA) — effective January 2024, most US companies must file beneficial ownership information with FinCEN (Financial Crimes Enforcement Network). This is not public — it's accessible only to law enforcement. Companies with a US office and 20+ employees are exempt.

AML: Bank Secrecy Act; FinCEN rules. Banks must collect beneficial ownership information for legal entity customers (companies). This is why Mercury asks for your company's beneficial owner details.

Note: The CTA has faced legal challenges. Verify current filing status at fincen.gov.

UAE

Beneficial ownership: The UAE introduced UBO regulations in 2020 requiring companies to maintain a register of beneficial owners and file with the relevant authority. Free zone companies must also maintain and file UBO information with their free zone authority.

AML: UAE's AML law and regulations are supervised by the Ministry of Economy (for DNFBPs) and the Central Bank (for financial institutions). The UAE was placed on FATF's "grey list" in 2022 and subsequently removed in June 2024 following implementation of extensive reforms.

Banking KYC: UAE banks apply rigorous KYC. For new free zone companies with non-resident owners, expect:

• Full passport copies for all shareholders, directors, and UBOs
• Proof of address (utility bills or bank statements)
• Company documents (licence, MOA, establishment card)
• Business plan or description of activities
• Source of funds explanation
• Sometimes: bank statements from other accounts, financial projections, client contracts

Singapore

Beneficial ownership: Companies Act requires Singapore companies to maintain a Register of Registrable Controllers (RORC) — effectively a UBO register. Filed with ACRA; accessible to law enforcement.

AML: MAS (Monetary Authority of Singapore) issues AML/CFT notices. Singapore consistently ranks among the world's most AML-compliant jurisdictions.

Banking KYC: MAS-licensed banks follow comprehensive KYC procedures. For corporate accounts, banks require: ACRA BizFile+ extract (the online company extract — can be downloaded from the ACRA website), Memorandum and Articles, identification for all directors, shareholders, and UBOs, and detailed business descriptions.

BVI / Cayman Islands / Offshore Jurisdictions

Beneficial ownership: BVI has implemented a beneficial ownership Secure Search System (BOSS) accessible to competent authorities from partner jurisdictions. Not publicly accessible but shareable under international information exchange agreements.

Cayman Islands maintains a beneficial ownership register accessible to Cayman authorities; accessible to partner jurisdictions under bilateral agreements.

UK pressure: The British government has sought to mandate public beneficial ownership registers for UK Overseas Territories (which includes BVI and Cayman). Implementation has faced delays. Check current status.

Banking KYC in practice: Opening a bank account for a standalone BVI or Cayman company is extremely difficult. Banks in reputable jurisdictions (UK, Singapore, Hong Kong, US) apply the highest level of due diligence to offshore companies. You will typically need:

• Full corporate documentation
• All UBO documentation
• Detailed explanation of the corporate structure and purpose
• Source of funds documentation
• Confirmation that the structure has genuine commercial purpose

This is why offshore companies are typically banked through an onshore operating entity — the offshore holding company has minimal banking needs (receiving dividends from the onshore entity), while the onshore entity handles all client-facing banking.

CRS — Common Reporting Standard

The CRS (Common Reporting Standard), developed by the OECD and implemented by 100+ participating countries, requires financial institutions to automatically report information about foreign account holders to the account holders' home countries' tax authorities.

What this means in practice: If you're a German resident with a business bank account in Singapore, the Singapore bank will report your account details, balance, and income received to the German tax authority (Bundeszentralamt für Steuern) annually. You cannot hide a foreign bank account in a CRS-participating country from your home country's tax authority.

CRS-participating jurisdictions (as of 2026, note: verify current list): All EU member states, UK, Switzerland, Singapore, Hong Kong, Australia, New Zealand, Canada, UAE, Cayman Islands, BVI, Jersey, Guernsey, Isle of Man, Bermuda, Mauritius, Seychelles, and many others. The US participates in FATCA (a similar but different system) rather than CRS.

FATCA: Foreign Account Tax Compliance Act — a US law requiring foreign financial institutions to report information about accounts held by US persons to the IRS. The UAE has a FATCA agreement with the US. FATCA applies to US citizens and green card holders regardless of where they live.

Practical implication: International banking structures are no longer private from tax authorities. This does not mean they are illegal — it means tax compliance in your home country must incorporate your foreign company and banking arrangements honestly.