Greenstep 2021 24 web

KYC - what is it all about?

Knowing your customer and understanding your customer (KYC, Know Your Customer) mean the same thing. Both of them aim to learn about customers and prevent criminal activities, such as money laundering and the financing of terrorism. At Greenstep, we need to understand the business of each customer in order to identify any potential abnormal transactions or misconduct. In addition, we need to know who the actual beneficiaries of the company are and whether there are politically influential persons among the actual beneficiaries, the board or the executive management.

Frequently asked questions

  • Who is an ultimate beneficial owner?
    The ultimate beneficial owner is a natural person who meets at least one of the following criteria:

    * Directly or indirectly owns more than 25% of the company's shares;
    * Directly or indirectly controls more than 25% of the company's voting rights; or
    * Exercises actual control over the company or organization for other reasons, such as a shareholder agreement, bylaws, or rules.

    If the ultimate beneficial owner cannot be identified, or if the above-mentioned conditions are not met, the beneficial owners are considered to be the board of directors or managing partners, CEO, or other person holding a similar position in the company or organization. For associations or foundations, the beneficial owners are considered to be the members of the board of directors or supervisory board registered in the association or foundation register. For apartment companies and mutual real estate companies, the beneficial owners are considered to be the members of the board of directors registered in the trade register.
  • Who is a politically exposed person?
    A politically exposed person is a natural person who has held a public position in Finland or a similar position abroad within the last 12 months in one of the following roles:

    * Head of state, head of government, minister, deputy or assistant minister, or state secretary
    * Member of parliament
    * Member of the governing body of a political party (chairperson, member, or alternate)
    * Member of the highest courts, the Constitutional Court, or other similar judicial body whose decisions cannot be appealed except in exceptional cases
    * President of the Supreme Court, court counselor, and military member in military matters
    * President of the Supreme Administrative Court, court counselor, environmental expert counselor, and chief engineer counselor of the labor court and labor court counselor and expert member of the judges of the insurance court
    * Assessor tasks in the Labor Court and Insurance Court
    * Alternate member of the aforementioned highest courts, the Constitutional Court, or other similar judicial bodies
    * Member of the Court of Auditors or the highest decision-making body that regulates the state's finances, corresponding to the National Audit Office in other countries
    * Member of the central bank's executive board
    * Ambassador, head of the representation, or chargé d'affaires
    * Commander of the armed forces, chief of staff, general, or admiral
    * Member or alternate member of the governing, management, or supervisory body of an entity wholly owned by the state
    * Secretary-General, chairman, member, or alternate member of an international organization
  • Who can do the identification on behalf of the customer?
    A person who has the legal authority to represent the company, i.e., signing authority
  • What does strong authentication mean?
    Identification of a person based on banking IDs or a passport or other official ID card.
  • Who can answer to the information request?
    A person who has a thorough knowledge of the company. The person does not need to have signing authority.
  • I received a request for information regarding a bankruptcy estate. What should I do?
    The bankruptcy estate has no ultimate beneficial owners. In the background questions of the information request, record that "represented by attorney N.N. from the law firm yy Ltd. No actual business activities or ultimate beneficial owners."
  • I received an information request but I’m no the right person to answer
    You can forward the information request within your organization to a person who is able to respond to the request.
  • I don’t understand what should I do
    You can contact the address We are happy to assist you in fulfilling your information request.