What is “Ongoing CDD”?
Ongoing Customer Due Diligence (OCDD) is a legally obligated perpetual KYC compliance procedure placed to ensure all financial institutions are informed of the up-to-date status of our merchants. As posed by 「ENFORCEMENT DECREE OF THE ACT ON REPORTING AND USING SPECIFIED FINANCIAL TRANSACTION INFORMATION」, Eximbay asks for all our merchants to participate the OCDD yearly basis.
Please note that temporary measurements such as remittance holding or accounts setting as dormant might be put in place in case of the following.
- A merchant refuses to submit the filled-out OCDD questionnaire
- A merchant refuses to provide documents of proof for beneficial ownership
- A merchant refuses to provide additional information for possible Eximbay’s request for Enhanced Due Diligence
- The result of OCDD shows a merchant or relevant person is matched to watch lists
1. General Information
The section ‘General Information’ is to collect and verify basic information of the CEO and the business. Please kindly fill in all requirements shown in the following parts.
- CEO information
- Business Info: All and Corporation · NPO/NGO
2. Beneficial Owner Information
A beneficial owner should be verified following step 1 through 3. This means that step 2 should be taken if no BO can be identified via step 1, and step 3 should be considered only if no BO is found from step 1 AND 2.
Once your BO is identified, please state the person’s information as requested in ‘BO Information section.
Also, it is crucial for all merchants to provide an appropriate document of proof to verify the stated BO.
Step 1)
- Identify a highest share-owning individual among the ones who owns more than 25% of ownership
- Select ‘Shareholders List’ as a document of proof and provide one accordingly.
※ How to identify the BO
Example 1)
|
Shareholder list of a merchant A |
Shareholder list of the Corp B |
|||
|
Shareholder |
Ownership |
Shareholder |
Ownership |
|
|
Corporate B |
90% |
Individual D |
60% |
|
|
Individual C |
10% |
Individual E |
40% |
|
Overall individual ownership for the merchant A
- Individual C: 10%
- Individual D: 54% (Corporate B ownership 90% * 60% = 54%)
- Individual E: 36% (Corporate B ownership 90% * 40% = 36%)
The beneficial owner of the merchant A: Individual D (The highest shareholder among 25% of ownership)
Example 2)
|
Shareholder list of a merchant A |
Shareholder list of the Corp B |
|||
|
Shareholder |
Ownership |
Shareholder |
Ownership |
|
|
Corporate B |
60% |
Individual D |
60% |
|
|
Individual C |
40% |
Individual E |
40% |
|
Overall individual ownership for the merchant A
- Individual C: 40%
- Individual D: 36% (Corporate B ownership 60% * 60% = 36%)
- Individual E: 24% (Corporate B ownership 60% * 40% = 24%)
The beneficial owner of the merchant A: Individual C (The highest shareholder among 25% of ownership)
Step 2)
- ①: State the highest shareowner in case there is no individual that owns more than 25% of shares.
Please be aware that the shareholder list is required as a document of proof in this case.
- ② or ③: Identify an adequate BO and provide relevant proof accordingly.
Step 3)
- Applies to NPOs and NGOs that are not able to identify a BO via steps 1 or 2.
- Fill out the ‘BO Information’ section except the “% of share owned” and provide an appropriate document of proof such as ‘Articles of Incorporation.’
3. Additional Information
- All: Specify the purpose of transactions placed via Eximbay’s payment platform, as well as the main source of funding for your business.
- Corporation · NPO/NGO: If the business is listed on a stock exchange, please let us know which exchange you are listed on.
Form Filler Information (Mandatory)
- Please make sure the form is filled, signed and dated by CEO