Due Diligence

VA Global Business has an obligation under the Prevention of Money Laundering & Terrorist Financing Regulations to ensure that we “Know Our Client” in order to protect ourselves in the event that any of our clients should use a global business structure for the purposes of money laundering, drug dealing, terrorist financing or any other illegal activity. When establishing a business relationship with a client and also on an ongoing basis, we are required to apply appropriate Customer Due Diligence measures on the business relationship, including identifying and verifying the identity of the client and all related parties.

Personal Identification Documentation:

• Proof of Identity:
  • Current valid passport
• Proof of current residential address:
  • A recent utility bill issued (dated less than 3 months)

  Note: PO Box addresses are not acceptable as residential addresses.

• Recent bank reference with mention of satisfactory records (dated less than 3 months)
  Note 1: The reference should be from a bank with whom the person has been banking for at least two years.
  Note 2: Bank reference letter from online bank is not accepted.
• Curriculum Vitae (CV)
  Note 1: Qualifications-From which Institution-Period of Time-Country.
  Note 2: Work experience for each job position till date-title-Company name-Country-Brief Description of Duties.
• Professional Reference (if available)
• Supporting documents to show source of Funds and Source of Wealth (any of the following):
  • • Bank Statements
    • Pay-slips
    • Inheritance Documents (if any)
    • Financial Statements of companies where the person is shareholder
    • Loan Arrangements

  Note: As proof of funds/Wealth, any one of the above can be provided (as applicable) or any other document which shows the source of funds for investments being made in the Global Business Company.

  “Source of funds”: Activity or transaction which generates the funds for a customer
  “Source of wealth”: Activities which have generated the total net worth of the customer.

Corporate Identification Documentation

• Certificate of Formation (Including Name, Incorporation number, Date of incorporation and Country of incorporation or registration)
• Official document showing registered office address and principal place of business
• Certificate of Current Standing if the entity is existing for more than 1 year
• The ownership and control structure
• Register of Directors, Shareholders and Secretary (as applicable)
• Identity of the principals including:
  • Promoters
  • Beneficial owners
  • Ultimate beneficial owners
  • Shareholders
  • Company Directors
    Note: The due diligence documents needed for the principals will be same as those for Personal Indentification Documentation
• Letter from the legal person to authorize a person to act on its behalf.
• Copy of the latest report and accounts if available (audited, where possible)
• Copy of the Memorandum & Articles of Association (if adopted).

Certification of documents

Where any of the Individual/Corporate Identification Document is not in an original form, the documentation must be appropriately certified as “true copies of the original documentation”.

Copies must be certified by a suitable person, such as an attorney, a lawyer, a notary, an actuary, an accountant or any other person holding a recognized professional qualification.

The certifier should sign the copy document and clearly indicate the date of certification, his name, address, position or capacity on it together with contact details (both email address and phone number) and where available, any registration number with any professional body.

Updated Due Diligence Documents

As part of on-going monitoring, updated Identification Documents will be required from existing clients. Valid passport is requested upon expiry, updated proof of address is requested yearly, updated bank reference letter is normally required every 3 years unless there is an exceptional reason for which the documents may be required earlier. Face-to-face meeting will be conducted at client onboarding stage and annually as part of ongoing compliance.

Guidelines for Digital Signature

The purpose of these Guidelines is to specify the minimum requirements which the Regulator would expect to be observed, with respect to the adoption of Digital Signatures as a means for electronically signing documents, in the course of the conduct of business activities.

Requirements:

• 1. The signatory shall be a natural person.
• 2. The digitally signed document shall be in the PDF format and the digital certificate used to sign the document should be issued by a Certificate Authority listed on the Adobe Approved Trust List (AATL).
• 3. The digital signature shall meet the PAdES LTV (PDF Advanced Electronic Signatures with Long-Term Validation) standard.
• 4. The validity of the digital signature shall be automatically verifiable within Adobe Reader/ Adobe Acrobat through the “Signature Panel”, “Certificate Details” and “Signature Validation” capabilities.
• 5. The security level of the digital signature must meet or exceed the security level required by the eIDAS regulation for Advanced Electronic Signatures (AES).
• 6. For record-keeping and auditing purposes, a Certificate of Completion (CoC) shall be generated and retained by the digital signature software for every digitally signed document.
• 7. The signed document shall include an embedded timestamp.

Note:

• Failure to comply with the requirements shall result in the non-acceptance of the digital signature by the Regulator.
• The digital signature software or service provider must, at a minimum, be ISO 27001³ and SOC 2 TYPE 2⁴ certified.

Confidentiality

All documents provided to VA Global are kept highly confidential and neither the statutory records of a global business company nor details on the company’s Shareholders and Beneficial Owners are publicly accessible. The only circumstances under which we are required to divulge such information are in response to a properly authorised investigation which has first been approved by the financial regulator of the jurisdiction concerned or which is required to be provided by law.

Please contact us for more information.