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Compliance

Context#

As a part of BPCE group, Xpollens is following the BPCE compliance group directives. Here after is an introduction of the different processes involved.

PEP and Sanction control#

Politically Exposed People (PEP)#

Those people, Politically Exposed Persons (PEPs), hold a crucial position in public and are vulnerable to financial crime.

Sanction People or organization#

Those persons, organizations or governments may have the potential to be involved in the financial activities which are:

  • Terrorism financing
  • Trafficking of narcotics
  • Violation of human rights
  • Money laundering
  • Proliferation of weapons
  • Violation of international contracts

Xpollens controls#

Xpollens performs both initial checks when the customer onboards and periodically during the customer contract. The identity is checked against international lists for both PEP and Sanction. Effects could be block the account or to get additional information from the customer.


Scoring#

Xpollens performs a scoring calculation based on customers informations. Main effect from a customer relationship perspective is the time between 2 KYC updates and differenciation in Banking activity controls.


Tax information control#

Process introduction#

To support governments to fight against tax evasion, financial institutions must implement solutions to collect a valid and credible self-certification in which their customers declare their tax information.

Xpollens is following the FATCA (Foreign Account Tax Compliance Act) and CRS (Common Reporting Standard) regulations and Xpollens does collect the tax information self-certification at the onboarding but also periodically or following an event, for update.

Retail customers and professionals detailled process#

At the customer onboarding, the tax informations and US relation are asked and are mandatories. The customers can provide up to 3 tax countries and Tax Idenfication Numbers (TIN).

See below that Xpollens fully automizes the self-certification generation, for very large majority of the Physical Person customers, no need to upload any document.

Here after are two examples :

  • First a non US customer providing its taxation information correctly in coherency with its personal informations.
  • Second an american customer providing its taxation information correctly in coherency with its personal informations.

Businesses detailled process#

As for retail and professionals, the tax informations and US relation are asked and are mandatories. The required informations depend on the customer activities. The processes below describe the non financial business process. For financial business (bank, hedgefunds,..), the tax information related to the business shareholders will be also required. Note that once required, up to 3 tax countries and Tax Idenfication Numbers (TIN) can be supplied.

For businesses, the self certification is not fully automated and will need to be supplied in pdf format. The self certification vs tax information will be part of KYC checks.

Here after are two examples for businesses that covers most of the business cases (ie non financial businesses) :

  • First a non US business customer providing its taxation information correctly in coherency with its personal informations and selfcertification.
  • Second an american business customer providing its taxation information correctly in coherency with its personal informations and selfcertification.
For financial businesses, each of the shareholders (more than 25% of shares) tax information will be asked. These informations will also be needed in the company selfcertification.

Endpoints#

You can provide tax information for check using this API :

If additionnal FATCA/CRS documents are required, the documents can be sent here using this API:


Once the Tax info has been validated, for physiccal persons you can retrieve the self certification here. This document should be available for the user at any time :


AML/FT control#

XPollens is processing operation screening and monitoring to secure the customers and fight against Money Laundering and terrorism Financing.. For example, operations IN coming from sensible geographies will be blocked or operation out to sensitive people..


Endpoints#

You can retrieve all the user compliance informations through a single API :

More information regarding this endpoint in the API reference.