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Due Diligence Requirements

Due Diligence for New Clients at Saxo Bank

Saxo Bank is required to comply with Danish regulations to prevent money laundering and terrorist financing as outlined in EU-directive 2005/60/EC and the FATF (Financial Action Task Force on Money Laundering). Saxo Bank is therefore obliged to apply stringent due diligence measures whenever a new client applies for an account, which must at least include:

Identifying the customer and verify identity based on documents, data or information obtained from a reliable and independent source
Identifying the beneficial owners where applicable
Obtaining information on the intended purpose and nature of the business relationship
Monitoring the ongoing business relationship, including the transactions made, ensuring that documents, data and information held are kept up-to-date

Requirements for Corporate Clients

Beneficial Owners

Saxo Bank must verify the identity of corporate legal entities and identify their beneficial owners. Submitted information must at least include:

individuals who directly or indirectly own or control the corporation or a sufficient percentage of the shares or voting rights. This includes ownership through bearer share holdings other than shares listed on regulated stock markets a — 25 % percentage is deemed sufficient to meet this criterion
individuals who otherwise exercises control over the management of a legal entity

For legal entities which administrate and distribute funds such as foundations and trusts:

where the beneficiaries have already been determined, any individuals who are the beneficiary of 25 % or more of the property of a legal arrangement or entity
where the beneficiaries not been determined, the group of persons that have the main interest in the legal entities

Exempt Financial Corporations

banking institutions
mortgage credit institutions
stock broking companies
investment management companies
life-assurance companies or lateral pension funds
savings undertakings
issuers of electronic money
investment associations, special-purpose associations, collective investment schemes, restricted associations, innovation associations and hedge associations
undertakings or persons whose activities are currency exchange or transfer of money and other assets

And corporations listed on a regulated stock exchange:

within the EU, Norway, Iceland or Lichtenstein. The EU list of regulated markets can be found here.
outside the EU listed on stock markets that are members of the World Federation of Exchanges (WFE) as listed here.

Documentation Required from Corporate Clients

Corporate clients must provide the following documentation to Saxo Bank as part of their account application:

Transcript from the local Commerce and Companies Agency

The certificate of incorporation or an equivalent document, confirming that the company is officially registered in the country of residency.

Articles of Association (or the equivalent)

These documents describe how the company is managed and operated and in different countries, are also known as “Articles of Association”, “Constitution”, “Bylaws”, “Operating Agreement”.

Documentation on signature authority on behalf of the corporation

This may be stated in the Articles of Association or in the transcript from the Commerce and Companies Agency. Otherwise we require a copy of the minutes from board meeting or similar defining the signatory rights.

Most recent audited annual accounts

Where the company has cannot present a financial statement for acceptable reasons, a statement of the financial status and suitability of the company for the type of trading it intends to undertake can be presented by the company's lawyers or auditors.

Language Letter

(if corporate documents are in another language than Danish or English)

The language letter certifies in English that the company is a registered company, describes the charter of the company according to the Articles of Association and the signatory authority.

The language letter can be drafted by Saxo Bank and must be authorized by the corporation's lawyer.

License (if applicable)

If funds to be deposited are not the proprietary funds of the corporation and are held on behalf of clients, then the corporation must submit a copy of the license authorizing it to hold such client funds.

The license must be in English or it must be possible to verify the license on the issuing authority's website (in English).

Proof of identity for all Authorized Signatories

A copy of an international passport or other official state ID for each of the Authorized Signatories. The submitted IDs must be valid and contain:

the signatory's name
an issue or expiry date
the signatory's signature