KYC, AML, sanctions, and beneficial owners
A risk-based onboarding and ongoing-monitoring standard for individuals, legal entities, beneficial owners, PEPs, sanctions, source of funds, and account restrictions.
The partner performs customer due diligence and asserts the outcome to MyStocks. That assertion must be
backed by retrievable evidence, a risk decision, and ongoing monitoring. A VERIFIED API value is not a
substitute for the underlying compliance work.
Risk-based, not checkbox-based
Apply controls in proportion to the customer, product, geography, ownership structure, funding path, and expected activity. A PEP match or higher-risk country is a review trigger, not an automatic finding of wrongdoing.
Control lifecycle
Individuals
At minimum, collect and verify legal name, date of birth, nationality, residential address, government identifier, tax residence, account purpose, occupation, expected funding, and source of funds. Validate that the person accepting terms and placing instructions is the verified customer or an authorised agent.
Use stronger checks where risk warrants them: liveness, document authenticity, database verification, proof of address, bank-account ownership, source-of-wealth evidence, or manual compliance review.
Legal persons and arrangements
Do not stop at the company registration record. Establish:
- Legal form, registration number, status, registered office, and operating address.
- Nature of business, account purpose, expected activity, and source of funds.
- Directors, trustees, partners, authorised signatories, and persons exercising control.
- The ownership chain through every intermediate entity to the ultimate natural persons.
- Beneficiaries, settlors, trustees, protectors, or equivalent parties for legal arrangements.
- Whether ownership/control information is adequate, accurate, current, and supported by independent evidence.
If no natural person meets the locally applicable ownership threshold, identify control through other means and record the senior managing official only where the governing rule permits it. Never treat a registry search alone as conclusive when the ownership structure or risk indicators require corroboration.
Screening and escalation
| Result | Required action | API state |
|---|---|---|
| Clear, standard risk | Complete documented approval | VERIFIED |
| Potential name match | Hold activity; resolve identity and match quality | PENDING |
| PEP or close associate | Enhanced due diligence and required senior approval | PENDING until approved |
| Sanctions match or legal prohibition | Do not transact; freeze/reject and escalate under applicable law | account restriction |
| Unexplained ownership/funding | Request evidence or decline relationship | PENDING or closed |
| Suspicious behaviour | Follow confidential reporting process; avoid tipping off | restricted as directed |
Screen customers, beneficial owners, controllers, representatives, and relevant payment counterparties. Re-screen on list updates and material events, not only at onboarding.
API assertion
Send the structured result only after completing your control:
Keep evidence references and reviewer identity in your compliance system. Do not place suspicious-activity reporting notes or sensitive investigative commentary in fields visible to general support staff.
Ongoing monitoring triggers
- Identity, nationality, address, tax residence, controller, or beneficial-owner change.
- Dormant account becoming active or a material deviation from expected volume.
- Rapid funding and withdrawal, third-party payments, circular flows, or unusual cross-border patterns.
- Repeated order cancellation, matched activity, market-abuse indicators, or unexplained losses.
- Sanctions/PEP list update, adverse media, law-enforcement request, or internal alert.
- Product expansion into higher-risk instruments, private markets, or a new jurisdiction.
Evidence required before production
| Control | Evidence |
|---|---|
| Customer acceptance policy | Approved risk appetite, prohibited relationships, and escalation thresholds |
| Screening | Provider coverage, list sources, matching logic, review SLA, and audit sample |
| Beneficial ownership | Ownership-chart standard and verification procedure |
| Monitoring | Scenarios, alert disposition, case permissions, and management reporting |
| Regulatory reporting | Named MLRO/compliance owner and confidential escalation channel |
| Quality assurance | Independent sample review and remediation tracking |
Reference standards
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