At Flexado, we think it is important to know our customers are and what their motivations for a business address are. In addition, compliance with AML legislation is essential. From experience we know that compliance can be a time-consuming and complicated process. Therefore, we make every effort to make the entire process as simple and friendly as possible for all parties involved. By combining over 15 years of experience with recent technological developments and by partnering with leading players from various industries, we have succeeded in fully automating this process. We ensure a complete file that is always up to date in a way that has never been easier.
Because Flexado provides business addresses and processes the resulting transactions, Flexado falls under anti-money laundering legislation.
In the Netherlands, this is the WWFT (Wet ter voorkoming van witwassen en financieren van terrorisme) and internationally, this legislation is referred to as the AML (Anti-Money Laundering).
It is a law aimed at preventing money laundering or terrorist financing. Companies covered by this legislation must take measures to prevent these practices and must comply with the obligations imposed by the law. These include customer due diligence and reporting unusual transactions. Failure to comply with legislation can lead to sanctions, fines or even criminal charges.
AML legislation applies worldwide and is often implemented in conjunction with Know Your Customer (KYC) and Know Your Business (KYB) guidelines.
Compliance &
submission of documents
1. Client survey
Companies must implement identification and verification procedures to establish the identity of their customers. This includes collecting information about the nature and purpose of the business relationship, monitoring it, and assessing the risks of the transaction.
How do we approach this?
The first step in client research is Know Your Customer (KYB). This involves collecting information on the company address, legal form, company registration number, shareholders, directors, business activities and other relevant data. By having insight into more than 180 trade registers with 200+ million companies, we easily and quickly map company structures.
Based on the resulting data, the individuals to be investigated are determined. The Know Your Customer (KYC) check. KYC requirements may vary from country to country, but generally the following information should be requested:
First name and surnameAddress detailsIdentification documentsVerification of identification documentsAdvanced biometric algorithms are used to verify whether the delivered documents are genuine and valid and if the person in question is also the person on the document. AI-driven ID verification is reviewed by expert reviewers, who monitor all automated ID verifications and remove possible system errors, fraud attempts or failures. The systems and processes used for this purpose are all ISO 27001, ISO 27017 and ISO 27018 certified. This ensures the quality of the process and the privacy protection of our customers.
2. Duty to report
Companies are obliged to report unusual transactions to the Financial Intelligence Unit (FIU). These are transactions that are suspected may be linked to money laundering or terrorist financing.
How do we approach this?
An unusual transaction is a transaction that deviates from a customer’s normal payment pattern and is suspected to be related to money laundering or terrorist financing. When such a transaction is spotted, it will be reported to the Financial Intelligence Unit (FIU) Netherlands. The FIU assesses whether there is a suspicion of money laundering or terrorist financing and may pass this information on to investigative agencies.
3. Internal procedures and controls
Companies must have effective internal procedures and controls to ensure proper compliance. This includes appointing a responsible person, training staff and establishing procedures and controls.
How do we approach this?
To ensure the integrity and quality of legal processes, Flexado relies on a number of key aspects and principles.
Legal8
Based on the resulting data, the individuals to be investigated are determined. The Know Your Customer (KYC) check. KYC requirements may vary from country to country, but generally the following information should be requested:
Training
To ensure that knowledge is always up to date, several training courses are attended annually (organised by Legal8). By requiring the entire Flexado team to attend these training courses, we ensure a broad understanding of (inter)national legislation and can guarantee the quality of our knowledge.
Duo control principle
The four-eyes principle, also known as the dual control principle, is an important concept applied to reduce risks and errors and to prevent fraud. The principle means that any transaction or action that is potentially risky should be monitored by at least two people. The duo control principle is an important measure to ensure the integrity and security of business processes.
Compliance Officer
Full compliance is under the watchful eye of the compliance officer. This officer is specially trained, educated and equipped with far-reaching knowledge of domestic and foreign legislation and case law. The compliance officer ensures that internal processes comply with legal requirements and also maintains contact with external parties.
The Chambre of Commerce
In consultation with the Chamber of Commerce, we regularly check for changes in the requirements for business registration addresses.
4. Retention period
Firms must keep records of their customer due diligence, transactions and reports for five years.
How do we approach this?
All documents are kept in accordance with the AML for up to 5 years after the termination of the agreement between Flexado and the client. After this period, the documents will be destroyed. For all questions about the GDPR (general data protection regulation) and document retention periods, please refer to our privacy policy.
5. Sanctions
Companies must impose sanctions on individuals or entities that fail to comply with anti-money laundering laws. This can range from a warning to termination of the business relationship.
How do we approach this?
If matters are not in line with the legislation, for whatever reason, the agreement between Flexado and the customer will be unilaterally terminated immediately, without further reason. In this way, we guarantee the quality of our customer due diligence.
Risk analysis
Flexado has conducted a comprehensive risk analysis that determines the risk categories under which customers fall, based on various factors and the corresponding measures. Download the full risk analysis below.
