Guidance for Completing the Client Identification Form
This Client Identification Form is intended to guide you through the key information required to understand the structure and activities of the Declarant Entity, including its legal form, business activities, regulatory status, ownership structure, and Ultimate Beneficial Owner(s) (UBOs).
Providing clear and accurate information helps streamline the onboarding process and ensures alignment with regulatory standards. For this purpose, we invite you to rely on official registration documents and, if helpful, consult your compliance or legal adviser.
Section 2.2: Declarant Entity Type
What is expected?
Please “type of entity” refers to the economic function or nature of the “Declarant Entity”. This helps us understand the legal structure of the “Declarant Entity”.
Examples of Entity Types:
- SOPARFI, Holding company (general / foreign), Investment holding company, SPF…
- Regulated or non-regulated fund: Alternative Investment Fund (AIF), (UCITS, RAIF, SIF, SICAV, SICAR), Fund management company / AIFM
- SPV (Special Purpose Vehicle), Issuing vehicle, Securitization vehicle, …
Tip: If unsure, you may check the registration documents - in particular the corporate object of the entity- or consult your compliance advisor.
Section 2.3: Legal Form of the Declarant Entity
What is expected?
Please enter the legal form as shown on the Declarant Entity’s official documents (often an abbreviation), it refers to the company legal form of the “Declarant Entity”.
Examples of Legal Forms:
- SA, Sàrl, SCA, SCS,
- SCSp, FCP,
- ASBL, Foundation
- GmbH (Germany/Austria)
- (UK)
- /Corp. (USA/Canada)
- SPF (Family Wealth Management Company)
Tip: You may use the exact abbreviation or full legal form from the registration certificate of the “Declarant Entity”.
Section 2.8: Business activities
What is expected?
Please describe the main business activity (-ies) of the “Declarant Entity” as per articles of association or official registration. This should reflect the nature of its operations or services.
Examples of Business Activities:
- Banking & Financial Services
- Real Estate Investment
- Holding and Management of Participations
- Investment Activities
- Provision of Services (including Professional Services such as Legal, Consulting)
- Manufacturing & Distribution
- Technology & Software Development
- Non-Profit Activities
Section 2.9: Regulatory Status
What is expected?
Please indicate if “Declarant Entity” or any entity in its structure is:
- A listed company (please state where the entity is listed and whether the shares are widely held. If at least 75% of the shares are freely traded and no shareholder controls the company, no UBO may be identified; otherwise, UBO(s) must be disclosed).
- A regulated entity (approved by a national authority, e.g., CSSF, FCA, SEC).
- An investment advisor (authorized to provide investment advice).
- An AIFM (manages alternative investment funds under EU rules).
Why this matters:
Regulated or listed entities are subject to stricter compliance processes, thereby reducing AML/CFT risk.
How to respond:
- If applicable, select the category and provide details of that entity (name, role, registration number).
Tip: You may check the registration documents or consult your compliance advisor.
Section 2.10: Structure Chart
What is expected?
Please briefly describe how the Declarant Entity is owned and controlled, including who ultimately owns or controls it.
The structure may fall into one of the following categories (non-exhaustive): corporate, family/wealth, international group, non-profit, or start-up/fintech.
How to describe your structure:
Please indicate the type of structure (corporate, family/wealth, international group, non‑profit, start‑up/fintech).
If no structure chart is provided, please include:
- all entities involved in the ownership or control chain (e.g. parent companies, holding companies, subsidiaries);
- ownership percentages and/or control relationships, in particular in case of multiple layers or cross‑border ownership;
- any special arrangements affecting ownership or control (e.g. shareholder agreements, trusts).
Examples of structures:
- Corporate: SA, SARL, Holding Companies.
- Family Wealth: Trusts, SPF, Foundations.
- International Groups: Cross-border holdings, M&A setups.
- Non-Profit: ASBLs, NGOs.
- Start-up/Fintech: Fundraising vehicles, tech start-ups.
- …
Section 3.1. UBO
“Any natural person who ultimately owns or controls the customer or on whose behalf a transaction is being conducted.”
This definition combines direct and indirect ownership and effective control.
What is expected?
The goal is to identify any natural person who gets direct and indirect ownership and effective control.
The “Cascade Methodology” to identify UBO-s- (advised by CSSF the Luxembourg Regulator)
How to respond:
The CSSF requires a three-step cumulative approach -“Cascade Methodology”- to identify UBOs:
- Ownership Threshold
Identify any natural person who directly or indirectly owns more than 25% of shares, voting rights, or ownership interest in the entity. - Control by Other Means
If no one meets the ownership threshold, identify any person exercising control through other means, such as shareholder agreements, veto rights, or significant influence over management. - Senior Managing Official (Pseudo-UBO)
If no UBO is found under steps 1 and 2, and there is no suspicion of concealment, designate the senior managing official of the entity as the UBO.
Important: Steps 1 and 2 must be applied cumulatively before moving to step 3.
General Advice
Please contact your compliance team for assistance.