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List of Required Documents

Updated

Entity Types

a) Companies

  1. Certificate of Incorporation of the Company and/or Holding Company (as applicable).
  2. Copy of any regulatory/operating licenses held with the relevant authority(ies) (if applicable).
  3. Ownership Structure Chart of the group, clearly outlining the holding entities and/or natural persons with their respective percentage of shareholding or control.
  4. Documentation(1) evidencing persons who are:
    • authorised to operate the account.
    • authorised to represent the Company to open payment/electronic money accounts and handle communications during the onboarding process.
  5. Copy of Passports, Identity Cards and/or Residence Permits for(2):
    • Shareholders holding 25% or more of the shares or voting rights;
    • Judicial representatives of the Entity, as established in the M&As;
    • Authorised signatories and persons vested with the authority to represent the Entity, as established in the board resolution provided.
  6. Signed FATCA & CRS Self-Certification Forms (if applicable).
  7. In case of licensed entities which are also subject persons (including Gaming operators), the following documents/information will be requested(3):
    • AML/CFT Policy
    • Transaction Monitoring Policy & Procedure
    • Customer Acceptance Policy

(1) This documentation may be a Board resolution, a Power of Attorney, or any other legal document evidencing the above-mentioned authority.

(2) This information is only required when the UBO(s) and/or Authorised Signatory(ies) opt for a Manual IDVA process. The applicant may benefit from the digital IDVA process applied by Trumia as provided during the application process. For further information, please contact the client services team at clientservices@trumia.com.

(3) Additional industry-specific requirements and questionnaires may apply.

b) Partnership

  1. Certificate of incorporation.
  2. Deed of Partnership / Partnership Agreement reflecting voting rights held by the Partners / Ultimate Individual Owners.
  3. Ownership Structure Chart of the group, clearly outlining the holding entities and/or natural persons with their respective percentage of shareholding or control.

c) Foundation, Association or Voluntary Organisations

  1. Certificate of Registration issued by the Registrar for Legal Persons and/or Certificate of Registration issued by the Commissioner for Voluntary Organisations (if applicable).
  2. Signed copy of the Deed of Foundation OR The Organisation’s Constituting Document which should be signed by Legal Representatives.
  3. Signed copy of the Association Agreement/Statute.
  4. Certified copy of Identity Documentation and Proof of Address of, as applicable:
    • the Founder;
    • the Administrator(s);
    • members of the supervisory council/Board Members;
    • the Beneficiaries; and
    • Key Controller(s).
  5. Updated list of Administrators or Executive Committee Members stamped by the Registrar for Legal Persons or Commissioner of Voluntary Organisations (as applicable).

d) Trusts

  1. Copy of the trust instrument from the trustee or an extract of the relevant parts of the trust instrument.
  2. Copy of certified Identity Documentation and Proof of Address of, as applicable:
    • the settlor;
    • the trustee(s);
    • the protector;
    • the Beneficiaries; and
    • Key Controller(s).

Industry Specific Requirements

a) iGaming Operators or Payment Agents

  1. Supporting documentation to showcase the monitoring done by the B2B customer to confirm the location of its players.
  2. Collusion monitoring procedures.
  3. Full list of operational domains/websites.
  4. List of PSPs from which fund settlements are expected to take place in Trumia’s account.
  5. Latest audited financial statements or management accounts if the company is a start-up/within its first fiscal year of operation.
  6. Average transaction size processed (player deposit and player withdrawal).
  7. Breakdown of the respective percentage % of fund flows from the following payment sources/methods:
    • Bank Transfers
    • P2P (Peer-to-Peer) Payment Platforms
    • Card payments
    • Prepaid cards
    • Crypto
    • Cash
  8. Supporting documentation to verify the SOW of the UBO(s).
  9. Do you make use of physical establishment (agents) which provide services on the Company's behalf?
  10. If the company is in possession of a gaming license issued by a regulatory body outside the EU/EEA, a supplementary questionnaire needs to be compiled and signed by the entity’s MLRO.

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