# KYC/KYB Overview ## “KYB\_launch” level This procedure describes the initial stage of legal entity onboarding at Delos through the KYB process. At this stage, the company completes the **KYB\_launch** form in Sumsub, providing core corporate information, ownership details, business activity data, and other information required for the initial compliance assessment. **Step 1. Residence Country Confirmation and Privacy Notice** After opening the form, the user must select their country of residence: “All countries except the USA” or “United States of America.” Depending on the selected option, the relevant privacy and personal data processing notice is shown below. The user should review this information before proceeding to the next step.
**Step 2. Company Data** At this stage the company provides its main registration and contact details. The information must be complete, up to date, and consistent with official corporate documents, public registers, and the company’s public profile. * **Company name** The full legal name of the company should be provided exactly as shown in the certificate of incorporation or registry extract. A trade name, abbreviation, or informal name should not be provided instead of the full legal entity name. *Red flags:* the name does not match the registration documents, a different legal entity is listed, or there are unexplained differences with the website or registry. * **Country** The correct country of incorporation should be provided, or another country if the field is specifically set up for the country of main business activity. A country chosen only for convenience, or a group presence country instead of the correct one for the field, should not be used. *Red flags:* the country does not match the documents, the website and contacts point to a different jurisdiction, or the company avoids clarity on where it is incorporated and operates.
* **Alternative company names** All other names actually used by the company should be listed, such as a brand name, trading name, or short name. *Red flags:* many unrelated names, names not disclosed on the website or in documents, or attempts to hide links to another business. * **Entity type** The correct legal form of the company should be selected in line with the registration documents. *Red flags:* the entity type does not match the registry, the selected type is too generic or incorrect, or the structure becomes unclear. * **Registration number** The official company registration number from the state registry should be provided. A tax number, internal client number, or any other identifier should not be entered instead of the registration number. *Red flags:* the number cannot be found in the registry, the format does not match the country of incorporation, or the number belongs to another entity. * **Legal entity identifier (optional field)** The LEI code should be provided if the company has one. If not, the field should remain empty or be completed in line with the form logic. *Red flags:* the LEI belongs to another entity, the LEI status is inactive while claimed as active, or the LEI data does not match the company name. * **Tax id** The company’s valid tax identification number should be provided. *Red flags:* the number does not fit the jurisdiction, does not match the documents, or the company cannot reasonably explain why no tax number exists. * **Incorporated on** The official incorporation or registration date should be provided. The business start date, website launch date, or any unofficial date should not be entered instead of the incorporation date. *Red flags:* the date does not match the registry, the company claims a long operating history despite very recent incorporation, or there is confusion between group entities. * **Control scheme** A clear and transparent ownership and control structure should be provided, including shareholders, beneficial owners, parent companies, and any other controlling parties. The structure should not be incomplete or intentionally simplified in a way that hides key ownership layers. *Red flags:* no UBOs disclosed, nominee shareholders without explanation, trusts or holding companies without beneficial owner disclosure, or inconsistencies between the scheme and the supporting documents. * **Email** A working corporate email address used for communication with the company should be provided. It is not recommended to provide only personal email addresses such as Gmail, Yahoo, or Outlook if the company has its own domain. *Red flags:* only a personal email without explanation, an email unrelated to the company domain, or a contact belonging to a third party or external agent without a clear role. * **Phone** A valid company contact number or the number of an authorised representative should be provided. *Red flags:* the number is not in service, belongs to another country without explanation, or only a personal mobile number is used with no corporate contact details. * **Website** The company’s official website should be provided if one exists and is used in the business. A partner’s website, temporary page, empty domain, or broken link should not be provided without explanation. *Red flags:* no website for a supposedly active business, a recently created domain despite claims of long operating history, or a website that does not match the company name or business activity.
**“Type of entity” field** refers to the legal structure of the client. The selected option must match the registration documents, registry extract, constitutional documents, and the actual business structure. An incorrect selection may affect the review logic, especially for ownership, control, and required documents. * **Limited liability company** This option should be selected for companies where the liability of members is generally limited to their contribution to the capital. This often includes LLC, Ltd, OÜ, S.à r.l., d.o.o., and similar forms. It should not be selected if the company is a corporation, partnership, foundation, trust, or sole proprietor. *Red flags:* the type does not match the registration documents, the company presents itself as an LLC but is another legal form, or the member structure is unclear. * **Publicly listed company** This option should be selected for a public company whose shares are admitted to trading on a regulated exchange or recognised market. It should not be selected if the company only plans to go public, trades privately or over the counter, or is only a subsidiary of a listed group while not being listed itself. *Red flags:* the company claims listed status but cannot confirm the exchange, ticker, or listing; the company says it is listed while only the parent company is listed. * **Sole proprietor (not selected in this KYB flow)** * **Partnership** This option should be selected for partnerships where the business is carried on by two or more partners. This may include general partnerships, limited partnerships, and similar forms. It should not be selected if the organisation is registered as a corporation, LLC, trust, or foundation. *Red flags:* it is unclear who the partners are and who controls the business; the role of the general partner and limited partner is not disclosed; the ownership structure does not fit the selected type. * **Corporation** This option should be selected for corporations and joint-stock companies where the capital is usually divided into shares. This may include JSC, PLC, AG, S.A., and similar forms. It should not be selected if the client is an LLC, partnership, trust, or foundation. *Red flags:* the company selects corporation, but the documents show a limited liability company; shareholders are not disclosed; there is a complex control structure without explanation. * **Trust** This option should be selected for trusts and similar legal arrangements where assets are held by a trustee for the benefit of beneficiaries. It should not be selected for a normal operating company, holding company, or foundation without a trust structure. *Red flags:* the settlor, trustee, beneficiaries, or protector are not disclosed; the trust is used as a non-transparent layer; no trust deed or supporting documents are provided. * **Private Foundation** This option should be selected for private foundations, often used for holding assets, estate planning, or other private purposes. It should not be selected if the entity is a charity, nonprofit organisation, or a normal commercial company. *Red flags:* the founder, council/board, beneficiaries, or purpose are unclear; the foundation is effectively carrying out normal commercial activity without a clear reason; the structure appears to hide the UBO. * **Charity** This option should be selected for charitable organisations established for charitable purposes. It should not be selected if the organisation is simply non-profit without formal charity status, or if it is actually operating as a commercial business. *Red flags:* the entity claims charitable purpose, but the activity or flow of funds looks commercial; there is no proof of charity registration; donations are used in a non-transparent way. * **Nonprofit Organization** This option should be selected for non-profit organisations that do not distribute profits to members and operate for public, professional, cultural, educational, or other non-commercial purposes. It should not be selected if the organisation is a charity with a separate charitable status, or an ordinary commercial company. *Red flags:* the organisation is declared as non-profit but operates like a commercial business; funding sources, governance, or activity beneficiaries are unclear; the documents do not support non-profit status. * **Public Agencies or Authorities** This option should be selected for government bodies, public agencies, municipal bodies, and other official state or quasi-state institutions. It should not be selected if the organisation only works with government contracts or is indirectly state-owned but is legally registered as a normal company. *Red flags:* the client claims public authority status without evidence; the structure appears governmental, but the documents show a normal legal entity; the level of state control is unclear.
**Step 3. Company Documents** At this stage, the company must select and upload corporate documents that allow us to verify its registration, address, ownership structure, control structure, and, where relevant, the authority of its representative. All uploaded documents must be current, readable, complete, and consistent with the information provided in the previous step of the form. * **Company details** The company must upload a **Certificate of incorporation / registration** or a **recent excerpt from a state company registry**. This document should confirm the company’s existence, legal name, registration number, and, where available, date of incorporation. An outdated, cropped, unofficial, or unreadable document should not be uploaded. *Red flags:* the document does not match the form data, the document is too old, key company details are missing, or the document appears altered or incomplete. * **Other 1** The company must upload its **Memorandum / Articles of Association / incorporation / registration documents**. These documents help confirm the legal form of the company, its internal structure, and its basic governance rules. Drafts, unsigned versions, or documents that do not relate to the current legal entity should not be uploaded. *Red flags:* the constitutional documents contradict the form data, refer to another company, do not reflect the current structure, or appear outdated without explanation. * **Other 2** The company must upload a **Proof of address**. This document should confirm the registered address of the company, or another address if this is required by the review logic. An unverified address, a document without a date, a document without the address, or a document unrelated to the company should not be uploaded. *Red flags:* the address does not match the form or registry, a third-party address is used without explanation, or the address appears to be a virtual office in a high-risk context without a clear business reason. * **Ownership structure** The company must upload a **Shareholder registry** or another official document confirming its shareholders or members. This document should show the direct owners of the company and help trace the ownership chain to the ultimate beneficial owners. An unofficial chart without supporting evidence, an incomplete register, or a document without owner names should not be uploaded. *Red flags:* ownership percentages are missing, owners are hidden, nominee shareholders are present without explanation, or the structure does not match the control scheme or other documents. * **Control structure** The company must upload a **Director registry** or another document confirming the current directors or managing persons of the company. This document is used to verify the persons who formally control or manage the company. An outdated directors list, an internal spreadsheet without official support, or a document relating to another company should not be uploaded. *Red flags:* the directors do not match the registry or constitutional documents, unexplained corporate directors are involved, or control exercised through third parties is not disclosed. * **Representatives authorization (Optional)** Where relevant, the company may upload a **Power of attorney**, **Partnership agreement**, or another document confirming the authority of the person acting on behalf of the company. This document is needed if the form is completed by someone other than a director or another clearly authorised person. A generic document without onboarding or representation authority, or a document without signatures and date, should not be uploaded. *Red flags:* the representative acts without a clear legal basis, the scope of authority is too broad or unclear, the document is expired, unsigned, or does not cover the right to represent the company in dealings with a financial institution.
**Step 4. Associated Parties** At this stage, the company must add the individuals associated with its ownership, management, or representation. The information must be complete, up to date, and consistent with the corporate documents, ownership structure, and internal authority framework of the company. * **Authorized signatories** This section should include the individuals who are authorised to act on behalf of the company, sign documents, submit applications, or represent the company in its relationship with Delos. For each person, the following details must be provided: **First name, Last name, Middle name (if applicable), Date of birth, Email, Phone**. Individuals who are not actually authorised to act for the company, external consultants without a power of attorney, or nominal contacts with no clear role should not be listed. *Red flags:* the signatory is not mentioned in the corporate documents and has no supporting authorisation; the person is presented as an authorised signatory, but the company cannot confirm their authority; only intermediaries or third parties are listed without a transparent link to the company. * **UBOs** This section should include all individuals with direct or indirect ownership above 25%, as well as any other individuals who effectively control the company based on the structure. For each UBO, the following details must be provided: **First name, Last name, Date of birth, Email, Phone, Percentage of ownership**. *Red flags:* the ownership documents show a UBO, but the person is not listed in the form; ownership percentages do not reconcile to 100% where they should; nominee shareholders, trusts, or holding companies are present without disclosure of the ultimate individual owners; a UBO with more than 25% is declared, but is not supported by the registry or other documents. * **Directors** This section should include the current directors or other persons who formally manage the company. For each director, the following details must be provided: **First name, Last name, Date of birth, Email, Phone**. Former directors, administrative staff without a management role, or third parties who are not part of the company’s governing body should not be listed. *Red flags:* the directors do not match the director registry or company extract; not all directors are listed in the form; corporate or nominee directors are used without explanation; formal directors are listed, but the actual management appears to be exercised by other undisclosed persons.
**Important:** If the same individual acts as an **authorized signatory, director, and/or ultimate beneficial owner(UBO)**, there is no need to create separate entries for each role. In this case, all relevant roles should be selected using the checkboxes, and the individual’s details should be completed only once. This helps avoid duplication and reduces the risk of inconsistencies across multiple profiles for the same person.
**Step 5. KYB and Transaction Profile - Registered Address and Physical Address** At this stage, the company provides its registered address and physical business address. * **Registered Address** The full legal address of the company must be provided exactly as shown in the registry or incorporation documents. A different address should not be provided instead of the official registered address. *Red flags:* the address does not match the registry or proof of address; the address belongs to a corporate service provider or virtual office without explanation; the address is incomplete. * **Physical Address** The company must provide the actual address where the business is carried out. The registered address should not be repeated automatically if the business operates from a different location. *Red flags:* no physical address is provided despite active operations; the address appears nominal or postal-only; the address does not fit the stated business profile.
**Step 6. Jurisdiction & Regulatory Information** At this stage, the company discloses its main operating countries, expected payment geography, any connection to higher-risk industries, and its regulatory status. * **Primary countries where your company operates** The company should list up to 3 main countries where it genuinely operates. Future markets or countries with no real business connection should not be listed. *Red flags:* the countries do not match the website, addresses, or business description; high-risk jurisdictions are listed without explanation. * **Countries you will send funds to and receive funds from** The company should list the countries with which it expects to transact as part of its normal business activity. An overly broad or random list of countries should not be provided without a clear business rationale. *Red flags:* the payment geography does not match the business model; sanctioned, restricted, or high-risk countries are included without explanation. * **Does your business operate in any of the following higher-risk industries?** The company should select all applicable higher-risk categories, or choose **None** if none apply. **None** should not be selected if the business is directly or indirectly connected to one of the listed sectors. The categories in this section are: * **None** * **Adult Content / Adult Services** * **Controlled substances (excluding licensed cannabis)** * **Firearms / Weapons (licensed only)** * **Gambling / iGaming / Betting** * **Cannabis / CBD (licensed only)** * **Virtual Asset Mixing / Tumbling Services** * **Is your business currently licensed or registered with a financial regulator?** The company must choose the option that reflects its actual regulatory status: * **Yes – fully licensed by a financial regulator** * **Yes – registered with a regulator but not licensed** * **No – regulation is not required for our business activities** The answer should be supported by a licence, registration, or a clear legal rationale. *Red flags:* the regulatory status does not match the website, marketing, or business model; the company claims to be licensed or regulated without proof; or says regulation is not required even though the activity appears regulated. **Additional requirements for high-risk clients** If the company states that its business falls within one of the **higher-risk industries (Adult, Gambling, FX(Forex), Offshore, Unlicensed regulated activity, Crypto / VASP etc.)**, the following additional documents and details must be requested: 1. **AML / Compliance Policy** The company’s internal AML, compliance, or risk policy. *Red flags:* no policy is available; the document is too generic; it does not reflect the company’s actual activity. 1. **Audited Financial Statements** The latest audited financial statements. *Red flags:* no audited accounts are available without explanation; only management accounts are provided; the financials do not match the stated scale of the business. 1. **Group Ownership Chart** A full ownership structure chart up to the ultimate beneficial owners. *Red flags:* the structure is incomplete; UBOs are missing; nominee, trust, or offshore layers are present without proper disclosure. 1. **Regulatory License (if applicable)** Evidence of licence or regulatory registration, where the activity is regulated. *Red flags:* the company claims regulated activity but provides no licence; the licence belongs to another entity; the licence status is inactive. 1. **MLRO / Compliance Officer Contact** Contact details of the person responsible for AML / compliance: full name, position, email, and phone number. *Red flags:* no responsible person is appointed; only generic or inactive contacts are provided; the AML function appears purely formal. **Additional requirements for companies that are licensed or registered with a financial regulator** If in previous step the company selects either: * **Yes – fully licensed by a financial regulator**, or * **Yes – registered with a regulator but not licensed**, the application will open an additional regulatory information section. 1. **Regulatory License / Registration Certificate** The company should upload its regulatory licence, registration certificate, or another official document issued by the relevant authority. The document should clearly show, where applicable: * the legal name of the entity; * the issuing authority; * the licence or registration number; * the scope of regulated activity; * the current status of the licence / registration. If no formal document is available, the company should explain why in the free-text field provided. *Red flags:* \*\*\*\*the status claimed in the form is not supported by the document; the licence or registration belongs to another entity; the document is expired, inactive, suspended, or cannot be verified; the regulated activity shown does not match the company’s actual business model. 1. **Group Structure / Ownership Chart** The company should upload an ownership chart showing the full group structure, including any parent entities, intermediate holding companies, regulated affiliates, and ultimate beneficial owners. *If the chart was already provided earlier in the application, the company may skip this upload.* *Red flags:* the structure is incomplete; UBOs or parent entities are missing; nominee, trust, or offshore layers are not properly explained; the chart is inconsistent with other corporate documents or registry information. 1. **AML/KYC Policy Summary + Risk Assessment** The company should upload its internal AML/KYC policy, manual, or policy summary, together with its risk assessment or risk framework. If no formal document is available, the company should provide a brief written summary covering: * onboarding and customer due diligence controls; * sanctions and screening controls; * ongoing monitoring approach; * escalation / suspicious activity handling; * overall risk-rating methodology. *Red flags:* the policy is overly generic, clearly templated, outdated, or inconsistent with the company’s actual business model or stated regulatory profile; no risk assessment is available; key AML controls are missing or unclear. 1. **MLRO / Compliance Officer Details** The company should provide the details of its appointed MLRO or Compliance Officer responsible for AML/KYC oversight. The form should include: * full name; * role / title; * email address; * phone number; * country of residence; * start date in role. *Red flags:* no responsible person is identified; only a generic inbox is provided; the contact appears unrelated to the company; the AML/compliance function appears purely formal or unsupported. **Step 7. Business Clarification / Business Classification** At this stage, the company must indicate its primary business activity and provide the relevant NAICS code and description. This information is used to understand the company’s actual business model and compare it against its documents, website, licences, and expected transaction profile. * **What is your primary business activity?** The company must select the option that best describes its main line of business. The selected category should match the actual business model, the public description of the company, its website, corporate documents, and, where relevant, its licence. **Red flags:** the selected category does not match the website, product, or services; the company selects a lower-risk category even though it actually conducts regulated, crypto-related, or investment activity; **Other** is selected without a clear explanation. The categories in this section include, among others: * **U.S. Crypto MSB (Virtual Asset Services)** * **Non-U.S. Crypto MSB (Virtual Asset Services)** * **Retailer of non-durable consumer goods** * **Professional services (e.g., legal, consulting, accounting)** * **Family office / investment holding vehicle (PIC/PBC)** * **Investment fund / pooled investment vehicle** * **Proprietary trading firm** * **Personal trust** * **Blockchain / software company** * **Broker-dealer / OTC trading desk** * **Commodities trading firm** * **Investment advisor / asset manager** * **Lending or finance company** * **Other** * **NAICS code** The company must provide the relevant **6-digit NAICS code** for its primary business activity. A random code, an approximate code, or a code chosen only because it appears lower risk should not be used. * **NAICS code description** The company must provide the official, or at least accurately matching, description of the selected NAICS code. *Red flags:* the description does not match the code; the description conflicts with the actual business activity; the wording appears to simplify or obscure the real nature of the business. **Step 8. Transaction Profile (Assets Currently Held)** At this stage, the company provides the approximate current value of the assets it holds. This information is used to understand the overall scale of the business and to compare it with the stated activity, expected transaction profile, and financial documents. * **Current crypto assets balance (USD equivalent)** The company must select the approximate range that reflects the total current value of crypto assets held by the company. The selected range should not be understated, overstated, or clearly inconsistent with the scale of the business. **Available response options:** * **Up to $10K;** * **$10K - $100K;** * **$100K - $1M;** * **$1M - $10M;** * **$10M - $50M;** * **$50M - $250M;** * **Over $250M.** * **Current fiat balance (USD equivalent)** The company must select the approximate range that reflects the **total current fiat balances** held in bank, EMI, or payment accounts. A random range or a figure that does not match the company’s operating scale should not be selected. **Available response options:** * **Up to $10K;** * **$10K - $100K;** * **$100K - $1M;** * **$1M - $10M;** * **$10M - $50M;** * **$50M - $250M;** * **Over $250M.** **Step 9. Transaction Profile (Crypto Transactions – Per Month)\*** \***if the company does not have any crypto transactions, then it is acceptable to specify the minimum values, but filling in this field is mandatory.** At this stage, the company provides its expected monthly crypto transaction activity. This information is used to assess expected transaction volume and compare it with the company’s business model. * **Incoming crypto - number of transactions per month** The company must indicate the approximate number of incoming crypto transactions per month. **Available response options:** * **Up to 5;** * **5-10;** * **10-25;** * **More than 25.** *Red flags:* the company claims to run an active crypto business but reports only minimal incoming transactions without explanation; the number does not match the expected scale of the business. * **Outgoing crypto – number of transactions per month** The company must indicate the approximate number of outgoing crypto transactions per month. **Available response options:** * **Up to 5;** * **5-10;** * **10-25;** * **More than 25.** A random range that does not reflect the actual operating model should not be selected. *Red flags:* the outgoing activity does not fit the stated product, client profile, or business flow; the transaction count appears artificially understated. * **Incoming crypto – total value per month (USD equivalent)** The company must indicate the approximate total monthly value of incoming crypto transactions. **Available response options:** * **Up to $1K;** * **$1K - $100K;** * **$100K - $1M;** * **$1M - $5M;** * **Over $5M.** * **Outgoing crypto – total value per month (USD equivalent)** The company must indicate the approximate total monthly value of outgoing crypto transactions. **Available response options:** * **Up to $1K;** * **$1K - $100K;** * **$100K - $1M;** * **$1M - $5M;** * **Over $5M.** **Red flags:** the outgoing value does not match the number of transactions, business model, or expected payment flows; the company declares large crypto volumes without a clear source of funds or economic rationale. **Step 10. Transaction Profile (Fiat Transactions - Per Month)** At this stage, the company provides its expected monthly fiat transaction activity. The first two questions relate to the number of transactions per month, while the last two relate to the approximate total monthly transaction value in USD equivalent. This information is used to assess expected fiat transaction volume and compare it with the company’s business model. * **Incoming fiat - number of transactions per month** The company must indicate the approximate number of incoming fiat transactions per month. **Available response options:** * **Up to 5;** * **5-10;** * **10-25;** * **More than 25.** *Red flags:* the company claims active operations but reports only minimal incoming payments without explanation; the number does not match the expected scale of the business. * **Outgoing fiat - number of transactions per month** The company must indicate the approximate number of outgoing fiat transactions per month. **Available response options:** * **Up to 5;** * **5-10;** * **10-25;** * **More than 25.** *Red flags:* the outgoing activity does not fit the business flow, cost structure, or stated company profile; the transaction count appears artificially understated. * **Incoming fiat - total value per month (USD equivalent)** The company must indicate the approximate total monthly value of incoming fiat transactions. **Available response options:** * **Up to $1K;** * **$1K - $100K;** * **$100K - $1M;** * **$1M - $5M;** * **Over $5M.** *Red flags:* the total incoming value appears disproportionate to the number of transactions; the figure does not align with the stated business profile, financials, or expected payment flows. * **Outgoing fiat - total value per month (USD equivalent)** The company must indicate the approximate total monthly value of outgoing fiat transactions. **Available response options:** * **Up to $1K;** * **$1K - $100K;** * **$100K - $1M;** * **$1M - $5M;** * **Over $5M.** *Red flags:* the outgoing value does not match the number of transactions, business model, or expected payment flows; the declared volume is not supported by the scale of the business. **Step 11. Company Source of Wealth** The company must briefly explain how it accumulated its wealth over time. **The explanation should describe the main economic source or sources of the company’s wealth, for example:** * operating revenue and retained profits; * investment proceeds; * sale of business units or assets; * dividend income; * intra-group funding; * capital injections; * or other identifiable business-related sources. **The explanation should be specific enough to make it clear:** * what generated the company’s wealth; * whether the source is ongoing or one-off; * and how that source fits the company’s business profile and stage of development. **Generic answers such as:** * “business income”; * “company funds”; * “operating activity”; * “investments”; without further detail are usually not sufficient on their own. The company must upload at least one document supporting the declared source of wealth of the company. Where appropriate, the company may upload multiple documents if one document alone is not sufficient to provide a clear and complete explanation of how the company accumulated its wealth. **Examples may include:** * financial statements; * audited accounts; * management accounts; * sale agreements; * investment statements; * dividend records; * capital contribution documents; * parent / group funding documents; * or other reliable documents showing how the company accumulated value. The document should support the explanation provided in the free-text field and should help the reviewer understand the economic basis of the company’s wealth. **Red flags in this section may include:** * the explanation is vague or formulaic; * the company describes only current funds, but not how they were accumulated; * the explanation refers to the UBO’s personal wealth instead of the company’s wealth; * the uploaded document is unrelated to the explanation; * the document shows only a bank balance, with no explanation of origin; * the stated source of wealth does not fit the company’s business model or age; * the company claims retained profits or operating revenue, but available financials show little or no real activity; * the company refers to intra-group funding, but does not explain the origin or structure of that funding; * the document is outdated, incomplete, draft, unsigned, or otherwise unreliable.
**Step 12. Source & Flow of Funds** At this stage, the company must disclose its main source of funds, their origin, the approximate value of the business, the expected flow of funds, and the main counterparties. This information is used to assess the economic rationale of the business, the source of funds, and future transactional behaviour. * **Main source of funds** The company must select the main source of the funds that will be held and transacted through Delos. **Available response options:** * **Business revenue / company profit** * **Shareholder / owner capital** * **Investment funding** * **Loans / credit facilities** * **Sale of business or assets / real estate** * **Grants, donations or trust distributions** * **Other / exceptional income** *Red flags:* the selected source of funds does not match the business or company structure; business revenue is selected despite no active operations; shareholder capital is selected but there is no indication that funds were injected; exceptional income is selected without a clear explanation. * **Additional details on source of funds** The company must briefly explain: * who provides the funds; * when they were received; * in connection with which activity or event they arose. *Red flags:* the answer is fuzzy; there is no clear link between the source of funds and the company’s actual activity; it is unclear who is providing the funds; the timing of receipt does not appear logical. * **Approximate total value of your business (USD)** The company must select the range that best reflects the overall value of the business / equity value / valuation. The selected range should be reasonable in light of the size of the business, asset base, revenue profile, and stage of development. An overstated or understated valuation without economic rationale should not be selected. *Red flags:* the valuation is clearly inconsistent with the size of the business, revenue, assets, or company stage; a very high valuation is claimed without investors, financial documents, or other support. * **Please describe the flow of funds through your account** The company must describe where funds will come from and where they will be sent, including the transaction type, for example **B2B, B2C, or C2B**. The explanation should reflect the actual payment model of the business. *Red flags:* the flow of funds does not match the business model; there is no clear economic purpose for the transfers; it is unclear why Delos is needed for this specific flow of funds; the description appears artificially simplified. * **Who do you send and receive funds from?** The company must list up to three main counterparties for incoming and outgoing payments. If counterparties are not yet established, this should be clearly explained. Ideally, **name + country** should be provided for each counterparty. *Red flags:* the company cannot name any main counterparty despite having an active business; the listed counterparties do not fit the activity; the counterparties are located in high-risk jurisdictions without explanation; the incoming and outgoing flows do not match the stated business model. * **Company Bank Statement** The company must upload a bank statement for its main operating account covering at least the last 3 months (90 days) of activity. **The statement should clearly show:** * the full legal name of the company; * the account number / IBAN; * the bank name; * the transaction history for the relevant period. The preferred format is PDF or an official bank export. Screenshots are not preferred where an official document can be provided. If no bank statement is available, the company must briefly explain the reason. **This may be acceptable, for example, where:** * the company was only recently incorporated; * operations have not yet started; * the main account was opened only recently; * the activity is currently routed through another corporate account, which is clearly explained. *Red flags:* the statement is incomplete, cropped, or unreadable; the company name, account number, or bank name is not visible; no transaction history is shown; only a balance screen is provided, with no movement of funds; the document does not appear to be an official bank statement; the company claims to be active, but the account shows little or no activity without explanation; the explanation for the missing statement is vague, purely formal, or not credible.
**Step 13. Business Profile** At this stage, the company must explain why it wants to use Delos services, who its customers are, and provide evidence of active business operations. This information is used to verify the economic purpose of the onboarding and to compare the stated business model with the company’s actual activity. * **What is the primary purpose of using Delos services?** The company must briefly and clearly explain how it plans to use its Delos account. The answer should reflect the actual planned use cases, for example: partner and supplier settlements, customer payment collection, payroll, contractor payouts, treasury management, or other operational purposes. Overly broad wording such as “for business operations” or “for payments” without explaining the actual payment flows should not be used. *Red flags:* the purpose of using Delos is unclear; the description does not match the business model; the stated use cases appear overly broad, unrestricted, or economically illogical for the company. * **Who are your customers?** The company must describe its typical customer profile, for example: *B2B / B2C / C2B, SMEs, enterprise clients, marketplaces, funds, professional clients, and so on.* The answer should be specific enough and consistent with the website, services, and expected transaction profile. Answers such as “businesses” or “everyone” without further detail should not be used. *Red flags:* the customer profile does not match the stated business activity; the company cannot clearly explain who its customers are; the actual customer base appears higher risk than stated in the form. * **Proof of business activity** The company must upload two or more documents showing active business operations, such as: * **contract** * **invoice** * **purchase order** * **or other documents evidencing real business activity.** Documents should preferably be uploaded in **PDF** format, without screenshots where possible. The form also accepts **JPG, PNG, HEIC, WEBP, or PDF** up to **50 MB**. The documents must be readable, relate to the current legal entity, and support that the company is carrying out the stated activity. *Red flags:* no documents are provided to support business activity; the documents appear formalistic or prepared only for onboarding; the counterparties, values, or transaction purpose do not match the stated business model; the documents relate to another legal entity or to an outdated period. * **If you don’t have it available, briefly explain why** If supporting documents are not available, the company must briefly explain why. This may be acceptable, for example, for very early-stage companies, but the explanation must be logical and consistent with the rest of the application. *Red flags:* the company claims to be an active operating business but cannot provide any supporting document; the explanation for the missing documents is weak or inconsistent with the other answers in the form. **Step 14. UBO/Shareholder Source of Wealth and Additional supporting documents** * **Source of wealth of the main shareholder(s) / UBO(s)** This section is used to understand how the main shareholder / UBO accumulated their personal wealth. It relates specifically to the personal source of wealth of the main shareholder / ultimate beneficial owner, rather than: * the source of funds for a specific transaction; * the source of wealth of the company; * or the current availability of funds in a personal account only. The company must provide a brief explanation of how the main shareholder(s) or UBO(s) accumulated their personal wealth. The explanation should describe the main personal source(s) of wealth, for example: * employment income; * business activity; * dividends; * investments; * sale of assets or shares; * inheritance; * or other legitimate sources. The answer should be specific enough to make it clear: * what source or sources generated the personal wealth; * whether the source is ongoing or one-off; * and how that source fits the UBO’s profile and role in the company. The company must also upload the personal bank statement of the UBO / shareholder showing transaction history for the last 90 days. This document is used as supporting evidence to help confirm the UBO’s personal Source of Wealth. The statement should preferably show: * the name of the account holder; * the account number / IBAN, where available; * the bank name; * the transaction history for the relevant period; * sufficient information for the reviewer to compare the account activity with the declared wealth profile. Documents should preferably be uploaded in **PDF** format or as an official bank statement / bank export, without screenshots where possible. The form also accepts **JPG, PNG, HEIC, WEBP, or PDF** up to **50 MB**. The document must be readable, relate to the relevant UBO/shareholder, and support the explanation provided in the form. *Red flags:* the explanation is vague, formulaic, or overly generic; the company describes the company’s wealth instead of the UBO’s personal wealth; the UBO claims substantial personal wealth but does not explain how it was accumulated; the statement does not relate to the relevant UBO / shareholder; the account holder name, bank name, statement period, or transaction history is not visible; only a balance screen is provided, with no transaction movement; the statement is short, incomplete, cropped, or unreadable; the declared source of wealth does not fit the UBO’s profile, role, age, or known activity; the explanation refers to business profits, dividends, or investments, but the statement provides no supporting context at all; the document appears unofficial, edited, or otherwise unreliable. * **Additional supporting documents** Where relevant, the company may upload additional documents that may help complete the review faster, especially in complex ownership structures, if they have not provided it before. Examples include: * **parent company incorporation documents;** * **shareholder register;** * **ownership chart;** * **or other documents that help explain the structure, control, or business activity.** These documents are especially useful where the standard document pack is not enough to fully understand the client’s structure or activity. *Red flags:* the company structure remains unclear even after additional documents are provided; the documents contradict the information already submitted; the additional documents reveal a more complex or higher-risk structure than originally disclosed. **Step 15. Final Step - Verification of Associated Parties** After the form is completed, a final screen appears showing the business verification status and the list of associated individuals who still need to complete individual identity verification. The company verification cannot be completed until all required associated parties finish their personal verification. * **Verification required** This section shows the individuals whose identity verification is still pending. For each person, it usually displays: * name; * company role or roles, for example **Authorized signatory, UBO, Director**; * email address. These details must match the information previously added in the **Associated parties** section. Three buttons are shown below: * **Verify now** This button is used when the identity verification is started immediately. It is useful where the applicant completes the KYC flow as part of the same process. * **Send to email** This button sends the verification link to the relevant person by email. It is sent to the personal email address specified for that person in **Step 4. Associated Parties**. The email address must be valid and must belong to that specific associated party. * **Copy link** This button allows the verification link to be copied and shared manually. It is useful where the verification will be completed later or through another communication channel. **“Remind all pending applicants”** button \*\*\*\*resends a reminder to all individuals whose verification is still pending. It should be used where some associated parties did not complete the process immediately. At the bottom of the screen, the status of the main review blocks is shown, for example: * **Company details** * **Company documents** * **Questionnaire** This indicates that the business form and documents are already under review, but the final case decision still depends on completion of personal verification by all required individuals. If a user clicks “verify now,” a form for completing KYC will open. ## “basic\_KYC\_PoA” level This procedure describes the KYC verification process for an individual in Delos through Sumsub. The verification applies to individuals associated with a company, including UBOs, directors, authorised signatories, and other persons whose personal verification is required as part of onboarding. **Step 1. Landing Page and Consent to Start Verification** After opening the verification link, the user is taken to the Delos Financial verification landing page in Sumsub. This page displays a general notice explaining that the user is submitting confidential data to Delos Financial, after which they can proceed to the verification flow. Before the KYC process begins, the user is also shown a consent screen. To continue, the user must click “Agree and continue.” By doing so, the user confirms that they have reviewed the privacy notice and the personal data processing notice. For U.S. residents, an additional consent applies for the processing of personal data, including biometric data.
On the second landing page, the user may see the **“Get verified faster with Sumsub ID”** option. If the goal is to complete verification directly within the Delos flow and not create a Sumsub ID account, this toggle should remain off. The user can then click **Start verification** and continue with the standard KYC process.
**Step 2. Identity Document** The user selects the issuing country and the document type to be used for verification. Accepted options are: **driver’s license, ID card, residence permit, passport**. After the document is selected, the system shows brief image quality guidance: the document should be captured in good lighting, without reflections, and without editing the image. **Step 3. Selfie / Liveness Check** After uploading the identity document, the user completes the liveness check. At this stage, the user must take a selfie / complete a face check using the camera. The face must be clearly visible, positioned within the frame, and without hats, glasses, or masks. **Step 4. Proof of Address** At the final stage, the user uploads a document confirming their residential address. The document must show the user’s name and address and must be current. The most popular accepted document types include: * **valid ID document with address details;** * **bank documents (last 3 months);** * **utility bills (last 3 months);** * **government-issued documents (last 3 months).** **General POA review rules:** * POA document should not be automatically rejected only because its country differs from the country of the identity document used for POI. * Multi-page documents are accepted. * Documents in all languages are accepted. * Screenshots are less preferable than original files and should not be accepted as POA, so in some cases Sumsub may reject them. Customers should provide the original document file or an official export wherever available. * **Countries and territories** POA is not accepted if the document is issued in any of the following countries: Afghanistan, Belarus, Cuba, North Korea, Haiti, Iran, Iraq, Myanmar, Nepal, Libya, Nicaragua, Russia, Syria, Venezuela, Yemen, Zimbabwe. * The system allows all of our accepted identity documents (**ID card, Passport, Residence permit, Driver’s license**) to be used as proof of address documents where they contain address information. At the same time the same document should not be used for both Proof of Identity and Proof of Address. **Accepted POA document categories:** POA may be confirmed using following the most popular document categories: * **Government organization** * Statement * Voter registration * Tax bill * **Utility provider** * Telecom * Utility bill * **Bank** * Bank letter * Bank statement **BUT Neobank** (Revolut, N26, Monzo, Chime) **documents:** not accepted. * **Other** * Lease * **Mobile operator** This category is **not currently enabled** as an accepted POA source. As soon as the verification is completed, the following message will appear
## “KYC\_Launch\_Individuals” level This level applies to the onboarding of individual entrepreneurs / sole proprietors who operate in their own name and do not use a separate legal entity such as an LLC, Ltd, GmbH, or similar company structure. As part of this process, Delos collects the client’s personal details, business activity information, address data, source of funds, and expected transaction profile. The purpose of this review is to confirm the client’s identity, understand their business profile, and assess whether the stated activity is suitable for Delos. **Step 1. Landing Page and Consent to Start Verification** After opening the link, the user is taken to the Delos Financial verification landing page in Sumsub. This screen displays a notice explaining that the user is about to submit sensitive data to Delos Financial, and that if the link was received from a suspicious source, the process should be stopped and the company should be notified. Before the verification begins, the user is also shown the **Consent to Start Verification** screen. To proceed, the user must click **Agree and continue**. By doing so, the user confirms that they have reviewed the **Privacy Notice** and the **Notification to Processing of Personal Data**. For U.S. residents, an additional consent applies for the processing of personal data, including biometric data.
On the next screen, the user sees all verification stages they will need to complete: provide personal information, identity document, perform a liveness check, provide address information, and complete questionnaire. This screen gives the user a clear view of the full verification flow before it begins. If the user is expected to complete verification directly within the Delos flow and without creating a separate Sumsub ID, the **“Get verified faster with Sumsub ID”** toggle must be turned off. The user can then click **Start verification** and proceed with the standard flow.
**Step 2. Personal Information / Applicant Data** At this stage, the user provides their main personal details. The information must be complete, current, and consistent with the identity document that will be used later in the verification flow, as well as with the rest of the application. * **First name** The user’s first name must be entered exactly as shown in the identity document. Short forms, informal versions of the name, or a name different from the document should not be used. * **Last name** The user’s last name must be entered exactly as shown in the document. A shortened version, maiden name without explanation, or a surname different from the document should not be used. * **Middle name (Optional)** If the user has a middle name or additional name element, it should be entered as shown in the document. If no such name element exists, the field may be left blank. A middle name should not be added if it does not appear in the document, and no arbitrary value should be entered. * **Email** A valid personal email address must be provided, and the user must have access to it. Another person’s email, a general company email, or an intermediary’s email should not be used where the verification is for a specific individual. * **Tax Identification Number (TIN)** The user must provide the correct **Tax Identification Number**, where applicable in their jurisdiction. A random number, another person’s number, or a different identifier should not be used instead of the TIN. * **Contact number** A valid phone number must be provided together with the correct international country code. Another person’s number, a temporary number without access, or a number not linked to the user should not be used.
**Step 3. Identity Document** At this stage, the user selects the issuing country and the document type that will be used for identity verification. The selected details must match the actual document that will be provided. * **Issuing country** The user must select the country that actually issued the document. The country of residence, nationality, or any other country should not be selected unless it is also the issuing country of the document. * **Document type** The user must select one of the accepted document types: * ID card * Residence permit * Passport The selected option must match the document that will be uploaded in the next step.
**Step 4. Selfie / Liveness Check** At this stage, the user must complete the liveness check using the camera. This step is performed to confirm that the verification is being completed by a real person and not by using a static image or a third party. Before starting, the system shows brief instructions: * choose a well-lit place * make sure the face is fully within the frame * do not wear hats, glasses, or masks The user should not complete the check in a dark environment, with the face covered, or using a poor-quality camera.
**Step 5. Proof of Address** At this stage, the user must upload a document confirming their residential address. The document must show the user’s address, be readable, and be current. The following document types are accepted: * valid ID document with address details * bank documents (last 3 months) * utility bills (last 3 months) * government-issued documents (last 3 months) Accepted upload formats are **JPG, PNG, HEIC, WEBP, or PDF** up to **50 MB**. A document without an address, an outdated document, or a file that does not clearly link the address to the individual should not be uploaded.
If one document is not sufficient, an **Additional page (Optional)** field appears after the main file is uploaded. This allows the user to add another page or supporting file where the address, name, or other important details are not fully visible in the first document. **Step 6. Jurisdiction & Regulatory Information** At this stage, the user indicates the countries with which they expect to send and receive funds and confirms whether their activity falls within one or more higher-risk industries. This information is used for the initial assessment of geographic and industry risk. * **Countries you will send funds to and receive funds from** The user must list the countries with which they expect to transact as part of their normal activity. The user should select up to 3 countries. **Red flags:** the stated geography does not match the activity profile; high-risk or restricted jurisdictions are included without explanation; the user cannot explain why transactions are expected with those countries. * **Do you operate in any of the following higher-risk industries?** The user must select all applicable higher-risk categories, or choose “None” if none apply. “None” should not be selected if the activity is directly or indirectly connected to one of the listed categories. **Available options:** * None * Adult Content / Adult Services * Controlled substances (excluding licensed cannabis) * Firearms / Weapons (licensed only) * Gambling / iGaming / Betting * Cannabis / CBD (licensed only) * Virtual Asset Mixing / Tumbling Services **Step 7. Source of Funds and Wealth** At this stage, the user discloses the primary source of the funds that will be used with Delos and briefly explains how their overall wealth has been accumulated. Additional information is also collected on the user’s employment status, employer or business, and current occupation. * **What is the primary source of the funds you will use with Delos?** The user must select the main source of the funds that will be deposited to or used through the Delos account. **Available response options:** * Salary / employment income * Self-employment / business income * Savings from income * Investment income / dividends / capital gains * Sale of property / business / other major asset * Inheritance / gift / trust distributions * Pension / retirement income * Loan / credit facility * Other The selected option must reflect the actual source of funds and should be consistent with the user’s profile, employment status, and further explanations. * **If you choose "Other" please specify** If the user selects **“Other”**, they must explain what the source of funds actually is. The answer should be specific and understandable. * **Please describe how you have accumulated your overall wealth** The user must briefly explain how their overall wealth was accumulated. This may include employment, business ownership, savings over time, investments, sale of assets, inheritance, or other understandable sources of wealth. * **Employment status** The user must indicate their current employment status. The answer should be consistent with the rest of the form, especially the employer / business name and occupation / job title. * **Employer or business name** The user must provide the name of their employer or, if self-employed, the name of their business or trading name. The field should not be treated formally or filled with generic wording such as “self-employed” instead of the actual business name. * **Occupation / job title** The user must state their current occupation or job title. The answer should be reasonably specific, for example: **Software engineer** or **Restaurant owner**. **Step 8. Transaction Profile (Assets Currently Held)** At this stage, the user provides the approximate current value of the assets they currently hold. This information is used to understand the overall financial profile of the client and to compare it with the stated source of funds, wealth profile, and expected transaction activity. * **Current crypto assets balance (USD equivalent)** The user must select the approximate range that reflects the total current value of crypto assets they currently hold. **Available response options:** * **Up to $10K;** * **$10K - $100K;** * **$100K - $1M;** * **$1M - $10M;** * **$10M - $50M;** * **$50M - $250M;** * **Over $250M.** *Red flags:* a significant digital asset balance is declared despite no crypto-related activity; the figure does not align with the source of funds, wealth profile, or later transaction profile; the user indicates crypto exposure but reports no or minimal holdings without explanation. * **Current fiat balance (USD equivalent)** The user must select the approximate range that reflects the total current fiat balances they currently hold. **Available response options:** * **Up to $10K;** * **$10K - $100K;** * **$100K - $1M;** * **$1M - $10M;** * **$10M - $50M;** * **$50M - $250M;** * **Over $250M.** *Red flags:* the fiat balance appears unreasonably low or excessively high compared with the user’s occupation, source of funds, or wealth explanation; the figure is inconsistent with the rest of the questionnaire. **Step 9. Transaction Profile (Crypto Transactions – Per Month)\*** \***if the user does not have any crypto transactions, then it is acceptable to specify the minimum values, but filling in this field is mandatory.** * **Incoming crypto – number of transactions per month** The user must indicate the approximate number of incoming crypto transactions per month. **Available response options:** * **Up to 5;** * **5-10;** * **10-25;** * **More than 25.** *Red flags:* crypto-related activity is declared elsewhere, but this section is left entirely blank without explanation; the transaction count does not match the rest of the transaction profile. * **Outgoing crypto – number of transactions per month** The user must indicate the approximate number of outgoing crypto transactions per month. **Available response options:** * **Up to 5;** * **5-10;** * **10-25;** * **More than 25.** *Red flags:* the expected outgoing activity is inconsistent with the user’s activity profile or source of funds. * **Incoming crypto – total value per month (USD equivalent)** The user must indicate the approximate total monthly value of incoming crypto transactions. **Available response options:** * **Up to $1K;** * **$1K - $100K;** * **$100K - $1M;** * **$1M - $5M;** * **Over $5M.** *Red flags:* the amount appears disproportionate to the transaction count, wealth profile, or source of funds. * **Outgoing crypto – total value per month (USD equivalent)** The user must indicate the approximate total monthly value of outgoing crypto transactions. **Available response options:** * **Up to $1K;** * **$1K - $100K;** * **$100K - $1M;** * **$1M - $5M;** * **Over $5M.** *Red flags:* the amount does not align with the number of transactions, the customer profile, or the stated activity. **Step 10. Transaction Profile (Fiat Transactions – Per Month)** At this stage, the user provides their expected monthly fiat transaction activity. All fields in this section are mandatory and must be completed in line with the expected transaction profile. * **Incoming fiat – number of transactions per month** The user must indicate the expected number of incoming fiat transactions per month. **Available response options:** * **Up to 5;** * **5-10;** * **10-25;** * **More than 25.** *Red flags:* the number of incoming fiat transactions is inconsistent with the stated activity, source of funds, or other answers in the questionnaire. * **Outgoing fiat – number of transactions per month** The user must indicate the expected number of outgoing fiat transactions per month. **Available response options:** * **Up to 5;** * **5-10;** * **10-25;** * **More than 25.** *Red flags:* the expected outgoing activity does not align with the expected flow of funds, the user profile, or the stated intended use of Delos. * **Incoming fiat – total value per month (USD equivalent)** The user must indicate the expected total monthly value of incoming fiat transactions in USD equivalent. The amount should not be clearly inconsistent with the number of transactions or the user’s overall financial profile. **Available response options:** * **Up to $1K;** * **$1K - $100K;** * **$100K - $1M;** * **$1M - $5M;** * **Over $5M.** *Red flags:* the total incoming value appears disproportionate to the number of transactions, wealth profile, occupation, or source of funds. * **Outgoing fiat – total value per month (USD equivalent)** The user must indicate the expected total monthly value of outgoing fiat transactions in USD equivalent. The amount should not be inconsistent with the expected use of the account and the overall transaction profile. **Available response options:** * **Up to $1K;** * **$1K - $100K;** * **$100K - $1M;** * **$1M - $5M;** * **Over $5M.** *Red flags:* the total outgoing value does not align with the number of transactions, stated activity, expected payment flows, or the user’s overall financial profile. **Step 11. Business Profile** At this stage, the user describes how funds will move through the Delos account, who the main counterparties will be, what monthly transaction volumes are expected, and what the first transactions are likely to be once the account is active. This information is used to understand the intended use case and compare it with the user profile, source of funds, and transaction profile. * **Please describe the flow of funds through your account** The user must explain where the funds will come from and where they will be sent, including the transaction type, for example **B2B, B2C, or C2B**. *Red flags:* the flow of funds does not match the user profile; there is no clear economic purpose for the activity; the description is too general to understand the real use case. * **Who do you send and receive funds from?** The user must list up to three main counterparties for incoming and outgoing payments. If counterparties are not yet known, this should be explained separately. Ideally, name + country should be provided for each side. *Red flags:* the user cannot name any counterparty despite having active operations; the listed counterparties do not fit the payment profile; counterparties are located in high-risk jurisdictions without explanation. * **What are your expected monthly transaction volumes?** The user must estimate their typical monthly activity, including transaction frequency and total volumes for both fiat and crypto. *Red flags:* the expected monthly volumes do not match the previously stated transaction counts and values; the volumes appear economically inconsistent with the user profile. * **What will be your first transactions once your Delos account is active?** The user must briefly describe the expected **first transactions after account activation**, for example incoming funds, an initial transfer, exchange, or payment, together with approximate amounts. *Red flags:* the first transactions do not align with the source of funds, expected flow of funds, or stated use profile; the description appears artificial or templated. **Step 12. Final Step** Once the user completes all mandatory steps and answers all questionnaire fields, the application automatically moves to **review / verification in progress** status. The screen shows that the information is being checked and that the verification result will be displayed once the review is completed.
Once the verification is successfully completed, the user sees a confirmation screen stating that the profile has been verified. At this stage, a final message is displayed and the user may close the page — no further action is required from the user.
--- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://docs.delos.financial/baas-wiki/basics/kyc-kyb-overview.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. Use this mechanism when the answer is not explicitly present in the current page, you need clarification or additional context, or you want to retrieve related documentation sections.