When your client is a company, partnership, association or trust, your Customer Due Diligence (CDD) case needs to cover the people behind it. In OnboardMe these people are added to the case as participants.
Why add them to the case
One case covers the whole structure. The company or trust and everyone who owns, controls or acts for it are recorded together.
ID checks are reused. Link a participant to an existing client and their ID verification on file shows on the case, so you don't verify them twice.
Screening is set up for you. Each participant automatically gets a row in the sanctions and PEP screening section.
Types of participant
Type | Where | Who to add |
|---|---|---|
Beneficial owners | C2 | People who ultimately own or control the client, with their ownership or control percentage |
Controllers | C3 | People who control the client, for example directors or, for a trust, trustees and appointors |
Representatives | D2 | People authorised to act for the client, for example the person giving you instructions |
Add a participant
Open the case and go to the right section (C2, C3 or D2).
Choose one of:
Link existing client to search for someone who is already a client (type at least 3 characters).
Add person to type the details of someone who isn't a client.
Fill in the details:
Field | What to enter |
|---|---|
Full legal name | Filled in and locked when you link a client |
Ownership/control % | Beneficial owners only |
Country of residence | |
Control / role description | For beneficial owners and controllers, for example "Director" or "Trustee" |
Authority to act | For representatives, for example "Director with authority to sign" |
Evidence / verification notes | How you verified this person |
Click Save draft.
To copy your beneficial owners into controllers, click Copy from beneficial owners (C2) or Copy all from C2 in C3.
Using ID verification on file
A linked participant shows ID verification on file, with the status, method and Last verified date. If there's nothing on file you'll see "No identity verification on file for this client yet."
Click Set verification to record how you verified the person.
Click Edit verification to update an existing record.
The verification is saved against that person's client record, so it's available on their other cases too. ID verification certificates on file are added to the case PDF.
Tip: For people you'll verify regularly, such as directors of several client companies, create them as clients so you can link them and reuse their ID verification.
Identity and screening for each person
Once added, participants appear in:
D3. Beneficial owners and controllers, to record identity notes for each person. Someone who is both an owner and a controller appears once.
E1. Sanctions and PEP screening, with a row for each person to record the name searched, date, and sanctions and PEP results.
Asking the client for these details
You don't have to type everyone in yourself. For companies and trusts, the information request includes Beneficial owners and controllers and Authorised representatives by default. When the client submits, the people they list are added to the case for you. See Requesting information from your client.
Next steps
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