In accordance with Law 10/2010 on the prevention of money laundering in Spain and European Union regulations on due diligence, Bit2Me is legally obligated to reliably identify legal entities, their ultimate beneficial owners (UBO), and the origin of the funds they intend to operate with.
Providing these documents is a mandatory legal obligation to complete your corporate onboarding process. All documents must be sent in color, PDF format, and with good legibility.
- Basic requirements
- Founding deeds and modifications
- Shareholding structure (ultimate beneficial ownership / UBO)
- Official identification and signatories
- Proof of operational address (POBOA)
- Proof of source of funds (Source of Funds)
- LEI Code (Legal Entity Identifier)
- Special cases
- Additional requirements for obliged entities (Enhanced Due Diligence)
Basic requirements
Below, select the document type to see the exact requirements. Make sure to review the specifications based on whether your company resides in Spain or internationally (EU/Non-EU).
1. Founding Deeds and Modifications
- Companies in Spain: copy of the articles of incorporation duly registered in the Commercial Registry, including any subsequent articles of amendment or statutory modification (e.g., capital increases, change of name, change of address, or appointment of officers), if applicable.
- EU and Non-EU Companies (Good Standing): articles of incorporation or bylaws, attaching any subsequent corporate amendments or updates, if any.
2. Shareholding Structure (Ultimate Beneficial Ownership / UBO)
- Companies in Spain: ultimate beneficial ownership certificate or registry certification issued by the Commercial Registry.
- EU and Non-EU Companies: official document detailing the ownership and control structure down to the ultimate beneficial owners.
3. Official Identification and Signatories
- Official identification: color ID card (DNI) or passport (both sides) of all partners/shareholders with more than 25% participation (UBO) and of the administrators/directors.
- Additional signatories (if applicable): copy of official identification (color ID card/passport, both sides) and a notarized power of attorney or authorization signed by the administrator or a director of the entity.
4. Proof of Operational Address (POBOA)
We need a document confirming the company's physical address, not older than 6 months. To facilitate the process, we accept any of the following:
- Utility bill or service receipt (water, electricity, internet, etc.) in the company's name.
- Bank statement from a corporate account.
- Registered lease agreement for the office/operational premises.
5. Proof of Source of Funds (Source of Funds)
Documentation justifying the origin of funds intended for operations.
- Tax documentation (main requirement): In Spain, it is necessary to provide Models 200, 390, or 303. For other jurisdictions, the annual Corporate Income Tax return for the previous fiscal year.
- Additional documentation (depending on operations or volume): depending on the type of company and expected transactional volume, our team may request the following supplementary documents:
- Commercial documentation: signed contracts with clients accompanied by a bank statement verifying the company as the beneficiary of the funds.
- Accounting documentation: recent annual accounts.
6. LEI Code (Legal Entity Identifier)
- Regulatory requirement: certificate of active/valid LEI code or proof of application.
- This requirement is essential for operating and especially required for companies incorporated within the European Economic Area. In Spain, it can be processed on the LEI Web Portal of the College of Registrars.
Special cases
Depending on the nature of your company, we may require specific documentation:
- Newly established companies (less than 8 months old): the initial share capital will be assessed based on the first operation.
- Asset-holding companies: Personal Income Tax (IRPF) declaration of the partners is required.
- NGOs / non-profit organizations: Model 182, informative declaration, or proof of received donations.
Additional requirements for obliged entities (Enhanced Due Diligence)
If your entity is legally classified as an Obliged Entity in its jurisdiction, in addition to the basic requirements, you must provide the following documentation to pass enhanced due diligence:
- Registration with the competent authority (AML / FIU / SEPBLAC): accreditation or proof of registration with SEPBLAC (in Spain) or with the main anti-money laundering authority (FIU) in your country of incorporation.
- Appointment of AML representative: document formally designating the representative responsible before SEPBLAC or the competent authority.
- Compliance Officer: full name, details, and identification of the person responsible for ensuring regulatory compliance within the company.
- Anti-Money Laundering (AML) policy: full copy of the document detailing the implemented policies, including KYC (Know Your Customer) processes and transaction monitoring mechanisms (KYT).
- KYC/KYT contract: contract or invoices for the KYC and KYT tools used by your company.
- External audit report: copy of the most recent report related to AML compliance.
- Risk analysis document: detailed assessment of the risks associated with the company's operations and measures to mitigate them.
- VASP / CASP registration (if applicable): evidence and proof of registration as a virtual asset service provider or virtual currency exchange, if applicable to your activity.
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