Paused Order Process

1. Allocation: MLC Verifier (normally Verginia or substitute) will add all orders requiring to be paused to the “Hayley Tab of Paused Master Sheet. Following completion of (2), order should be moved to the following tabs: Turkish Clients – Niviena Overseas Corporates – Colin All others – On-going   2. Verification 2.1 Standard Verification   Hayley (or substitute) should verify the structure of the proposed company to ascertain what documentation is required and for whom (please see separate document “Verifying Guidance”).  Certified ID & Proof of Address should be requested for the following people:   All 25%+ shareholders who have failed our digital MLC checks, or on whom these could not be run (e.g. Non-UK Residents.) The customer, if they have failed our digital MLC checks. Any director, secretary or PSC who is using our address as their correspondence address, if they have failed our digital MLC checks. Customer + all 25%+ shareholders regardless of success of digital MLC checks when any of the following services are present:   Business Address; Full Company Secretary Service (FCSS)   2.2 Verification of Corporate Shareholders When a corporate shareholder is present in the proposed structure of a company, this should be verified in the following manner:   For UK Corporate entities, consult the public record on Companies House to ascertain any shareholder who ultimately owns 25%+ of the proposed new company indirectly.    For Non-UK corporate shareholders, or UK corporate shareholders which lead back to non-UK corporate shareholders or otherwise opaque structures which do not allow us to confidently determine the UBOs, documentation detailing this must be requested from the customer during step 3.   3. Client Contact:  Once all relevant parties have been identified, email should be issued to request the appropriate certified ID & address documentation from the individuals/entities necessary.    Credas invitations should be issued to all identified natural persons to facilitate the quick and easy completion of certified ID stage of these requirements.   Email will then direct client to supply their proof of address documentation via a Jotform link which will also contain our business information questionnaire, ensuring that necessary purpose of business, source of funds and other information is obtained via this step.   4. Assessing Documentation Supplied   4.1 Credas:  When a Credas check is completed this must be reviewed manually by the team member, even if the result is a pass.  The team member should ensure the following:   The Visual Analysis and/or NFC Chip has passed* The Facial match has passed** The name check has passed**   * Credas will often approve images of printed documents, or documents displayed on computer screens.  We DO NOT accept such documents.  In such instances, the client should be contacted and asked to upload an image of the physical document directly. ** It is common for these checks to fail for various reasons.  For example, if a person has aged considerably, or changed their appearance since their ID photo was taken (e.g. grown a beard).  Also, the name check may often fail as the ID contains middle names we have not included in the check ourselves.  In both cases, the team member may override these checks and pass the order, provided they are satisfied it is the same person and the details are correct.  Under no circumstances should a Team Member override a visual analysis or NFC Chip result, however.   4.2 Manually Certified ID   Clients who do not wish to use Credas may still provide manually certified copies of their photo ID instead.  In many instances, particularly outside the UK, there will be standard methods of completing such certification, and team members should familiarise themselves with the most common forms we receive (Morocco, India, France etc.).   Generally speaking, however, and for UK clients in particular, the certification should take the following form:   A photocopy of the original document should be made by the certifier.* The certifier should state in writing “certified to be a true copy of the original, seen by me” The certifier should then sign and date the document, and include their address, profession and – where appropriate – professional credentials (e.g. ACCA number for accountants).   Acceptable professionals who may certify documents within the UK/EU include:   The Post Office Lawyer Solicitor / notary Accountant Teacher / lecturer Minister of Religion Civil Servant Outwith the EU, we will generally require documentation to be notarised by a public notary, however in certain cases a solicitor or other professional may be acceptable where this is standard practice in the country in question (e.g. a Justice of the Peace in Australia, or Chef du Quartier in Benin).   *Certified documents must be direct photocopies of the document.  We cannot accept digital certification, or certification of printouts of digital photos.  This is because such formats usually indicate that the certifier has not in fact seen the original document, but simply received these digitally, defeating the purpose of certification.   4.3 Proof of address:  Proof of address documents should generally be provided in the form of a recent utility bill, bank statement, or, in the case of certain non-UK clients, certificates of residence.  Other documents may also be acceptable but should be run past the Head of Compliance if in any doubt.  In order to be accepted, all proof of address documents must meet the following criteria:   Be addressed directly to the individual for whom it is being supplied.  It cannot be addressed, for example, to their company or a family member. Be addressed to them at their current, home residential address.  Office addresses or PO Boxes etc. cannot be used for this purpose. Contain a clear date of issue within the last 3 months.   Please note, currently, for Moroccan residents, only a certificate of residence issued by the local Mairie can be accepted as proof of address.  This policy is subject to on-going review.   Proof of address documents must be provided either in the form of a photograph of an original, physical paper document received by post, or the original PDF download of a digital document.  Screenshots/mobile screengrabs of documents should not be accepted, nor should print-outs of online documents.   The team member should liaise with the customer until all documents have been supplied satisfactorily and should not process the order until all requirements are complete.   5. Processing the order:  Before processing the order, the team member should conduct a final review of the proposed structure, ensuring that all details, including the PSC register and any corporate details are accurate.  Once satisfied, the order should be placed on the corresponding Teams Channel in the format “Please Process – (Company Name)” where this will be picked up by the Order Reviews team for a final review and submission to Companies House.   The company entry in the on-going paused sheet should then be marked as complete and the current date added to the “date actioned” column.