KYB

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Standard KYB requirements

Company information

• Country
• Company name
• Registration number
• Legal address
• Type of entity
• Date of registration
• Website
• Company email
• Tax ID

Documents

• Company details (Doc type: Statement of information, Excerpt from a state company registry, Articles and memorandum of association, Incorporation certificate, Certificate of incumbency, Certificate of good standing)
• Ownership structure (Doc type: Shareholder registry, Statement of information, Trust agreement, Excerpt from a state company registry) The document must list all shareholders with their ownership percentages (totaling 100%), be dated within the last 12 months, and signed by a director unless publicly available.
  • KYC checks: Each UBO with 25%+ ownership and all company directors must complete KYC (Proof of ID + Proof of Address) and be individually approved before onboarding. If there is no UBO who owns 25%+, all UBOs with 10%+ ownership must be verified.
  • KYB checks: Apply to all legal entities in the ownership chain. For each additional entity, the same information is required unless ownership can be verified through open sources.
• Control and management structure (Doc type: Director registry, Trust agreement, Statement of information, Excerpt from a state company registry - any of these documents if it contains information about appointed directors)

Business detail

• Industry type
• Business model & target clients (nature of business, products/services, profile of customers)
• Main business countries of operation
• Licenses or registrations (financial, regulatory, or sector-specific)
• AML Program requirement (Yes/No) → if yes, upload Company’s AML Policy
• Estimated annual revenue (eur)

Source of Funds

• What is the source of the funds that will be used for transactions via the platform? (selector)
• Upload SoF document (This is not part of our standard onboarding, but it is mandatory for business customers who want to use SEPA third-party payouts via LHV.)

Planned Activities

• Purpose and intended use (for what purposes the platform will be used)
• Estimated monthly volume (expected transaction value)
• Estimated monthly transactions count (expected number of transactions)
• Do you send funds on behalf of customers? → if yes, explain Flow of Funds / add flow of funds chart

Associated Parties of Your Company

• UBO (Ultimate Beneficial Owner): Always a natural person. Direct or indirect ownership above 25% (or 10% in high-risk cases).
• Director: Individual(s) formally appointed as director(s). Representative: Authorized individual acting on behalf of the company.
• Shareholder (direct ownership above 25%; company). (E.g., Business Customer → owned by Company A → John Smith owns Company A → Company A is Shareholder, John Smith is UBO).
• UBO - always a natural person
• Shareholder - always a legal entity

Identity verification/Liveness Check for Director/authorized rep, UBO For business customers, there are typically 2–3 types of people to identify, depending on whether an authorized representative is appointed (a person with power of attorney who assists the director/management in opening the account):

• Director(s): ID collection + liveness check.
• UBO(s): Regulations usually require only ID collection. In high-risk cases a liveness check may also be required. Normally, UBOs are not subject to liveness checks unless they are also directors.
• Authorized representative (if appointed): ID collection + liveness check + power of attorney signed by the company’s director confirming authorization.

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Enhanced KYB Due Diligence

Business customer risk is defined through customer risk rating process - calculating the risk score based on number of different factors: geography, industry, use of product, expected activities, legal form etc

• KYB Information: Standard KYB
• UBO information: Individuals holding 10%
• Source of Wealth: Financial document outlining the corporate entities ability to continue business

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Appendix

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Prohibited Industries

To ensure alignment with regulatory expectations and Iron’s risk appetite, the following business activities are prohibited from using Iron’s services:

• Activities violating laws, such as hacking, drug trafficking, human trafficking, or counterfeit goods.
• Trading, producing, or facilitating firearms, explosives, or military-grade materials.
• Unregulated crypto exchanges, payment services, peer-to-peer platforms, and trust or company service providers.
• Gambling or betting platforms without proper licensing, including TOR-based or land-based operations.
• Darknet marketplace transactions, crypto mixers, and privacy coin transactions.
• Sale or distribution of banned CBD products, marijuana (where prohibited), and drug-related equipment.
• Escort services, pornography, and adult entertainment products.
• Fraudulent investment schemes, get-rich-quick schemes, and unauthorised MLM programs.
• Sale, trade, or facilitation of human organs or body parts.
• Items related to criminal activities or promoting illegal acts.
• Distribution or sale of explosives, toxic substances, or dangerous chemicals.
• Trade in counterfeit brands, piracy, or intellectual property infringements.
• Unregulated sales of liquor, legal counsel, or pharmaceuticals.
• Hacking tools or software developed for unlawful activities.
• Unauthorised cold-call marketing activities violating local privacy laws.
• Facilitating trading of in-game items for real-world currencies or crypto.
• Unauthorised crypto ATMs or mining operations issuing their own digital assets.
• Unauthorised physical or digital currency exchanges.
• Activities intended to bypass international sanctions.
• Facilitating ransomware transactions or ransomware-as-a-service operations.
• Donations involving charities that are unregistered or unverifiable

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Business Ownership and Constitutional Documents

To comply with Iron’s KYB requirements, all businesses must provide clear, official documentation that reliably verifies their complete ownership structure, ultimate beneficial owners (UBOs), controlling individuals, and confirms the existence and ongoing operations of the legal entity. If the entity does not have individual beneficial shareholders, we will need to confirm the individuals who significantly control the entity instead, such as its directors and officers. Includes rules for:

• Sole Proprietorships.
• Partnerships.
• LLCs & Corporations.
• Trusts.
• Nonprofits.
• DAOs.
• Cooperatives.

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Required Documentation per Entity Type

Sole Proprietorships

• Official sole proprietorship license or registration document clearly naming the sole proprietor and confirming active operation.
• Recent tax filings or official government-issued documents linking the proprietor to business operations.

Partnerships (General, Limited, LLP)

• Partnership agreements officially certified or notarized, detailing partners and ownership shares.
• Officially issued partnership registration certificates clearly listing partners and their shares

Limited Liability Companies (LLCs) and Corporations

• Articles of Incorporation or Articles of Organization issued by the official business registry, clearly listing shareholders/members.
• Official shareholder/membership register or certified extracts from commercial registries clearly indicating owners and ownership percentages.
• Share certificates officially verified or notarized.
• Recent audited financial statements (for publicly traded or regulated entities), confirming the company’s operations and ownership.

Trusts

• Official trust deed or certificate clearly identifying trustees, settlors, protectors (if applicable), and beneficiaries.
• Notarized trustee affidavit clearly verifying trustee identity, roles, and authorities

Nonprofit Organizations

• Official formation documents (e.g., Articles of Incorporation) clearly listing controlling individuals (e.g., directors or board members).
• Government-issued or officially filed annual reports or governance documents confirming ongoing operations and key individuals.

Decentralized Autonomous Organizations (DAOs)

• Official governance documents or independently audited membership agreements clearly outlining membership, control mechanisms, and operational status.

Cooperatives

• Official formation documents clearly identifying cooperative members.
• Independently certified membership ledgers or agreements clearly indicating members and voting rights.

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Acceptable Document Formats & Verification Standards

All provided documents must be issued by an official governmental authority and where applicable certified by a notary public, lawyer, auditor, or similar independent professional, with Apostille certification where applicable.

• General Documentation Standards: All provided documents must be officially issued by governmental authorities and must be verifiable online through an official registry or database. If online verification is not possible, the documents must be independently certified by a notary public, licensed attorney, auditor, or certified public accountant. If applicable, Apostille certification or equivalent legalization is required. Self-generated or internally-produced documents are NOT acceptable. Documents must clearly display the full legal name and registration code of the business entity. If the entity’s ownership structure involves more than two layers (entities owning other entities), a clear organizational chart indicating ownership percentages for each level must be provided. Documents must be recent (issued within the past three months). Documents not originally in English must include certified translations.
• The documents must clearly confirm: The legal existence of the entity. Its current operational status. Clear identification of ultimate beneficial owners, controlling individuals, and precise ownership percentages.
• Unacceptable Documents: Self-generated, internal, unsigned, or informal documents. Simple printouts, screenshots, or unofficial emails. Internally prepared capitalization tables unless provided by reputable equity management services

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Requirements for entities which are under regulatory supervision

• Entities that operate under regulatory supervision must provide additional documentation to confirm their licensing status and compliance with AML/CFT regulations. Regulated entities must submit the following:

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Regulatory Licenses and Authorizations

• A valid license or authorization issued by the relevant financial regulator or supervisory authority permitting the entity to conduct its business activities. If the license or authorization is not publicly accessible online, it must be certified by the issuing authority or a notary public.

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AML/CTF Policy and Procedures

A copy of the entity’s internal AML/CTF policy, outlining its approach to:

• Customer due diligence (CDD) and enhanced due diligence (EDD)
• Transaction monitoring processes
• Suspicious activity reporting procedures
• Sanctions screening and PEP checks
• The policy must be approved by senior management and aligned with the applicable jurisdiction’s AML laws and regulations.
• Licenses and authorizations must be verifiable online. If online verification is not possible, documents must be certified by the issuing authority, a notary public, or a licensed legal/audit professional.
• The submitted AML/CTF policy must be an officially approved internal document (not a draft or template).