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ID Requirements and Anti-Money Laundering Customer Due Diligence at The Start Up Shop

The Start-Up Shop is authorized by the Department of Justice & Law Reform to serve as a Trust & Corporate Service Provider. Accordingly, we are obligated to conduct Customer Due Diligence (“CDD”) for all our business relationships. This requirement extends to all company formations and specified company secretarial services that we offer.

Third-Party Confirmation

Under Section 40 of the Act, when a customer is introduced to The Start-Up Shop by a “relevant third party,” as defined in the Act, we can rely on the due diligence measures already conducted by that third party. A relevant third party is described as follows:

  • A credit institution
  • A financial institution
  • An external accountant or auditor who is a member of a designated accountancy body
  • A tax adviser who is also a solicitor or a member of a designated accountancy body or the Irish Taxation Institute
  • A relevant independent legal professional
  • A trust or company service provider who is also a member of a designated accountancy body, a solicitor, or authorized by the Central Bank and Financial Services Authority of Ireland
  • A person conducting business in another Member State or designated place under the Act and supervised or monitored in accordance with the Third Money Laundering Directive

Before providing specified company secretarial documentation, The Start-Up Shop will request the following written confirmation from the third party:

1. Confirmation as a relevant third party under the Criminal Justice (Money Laundering & Terrorist Financing) Act 2010.
2. Confirmation of having performed appropriate Customer Due Diligence in full compliance with the Criminal Justice (Money Laundering & Terrorist Financing) Act 2010 on this business relationship.
3. A commitment to forward any relevant documents or information related to the customer, obtained during the application of CDD, to The Start-Up Shop upon request.

Non-Third Parties

For non-third-party cases, The Start-Up Shop is required to conduct Enhanced Due Diligence as we do not meet the client in person during the Customer Due Diligence process. To meet these requirements, we need the following documentation:

  • Copies of passports or driver’s licenses for each Director and shareholder.
  • Copies of utility bills or bank/building society statements for each Director and shareholder.
  • Written confirmation of the beneficial owner of the company, including their name and address.

All of the above documentation must be certified by one of the following:

  • Peace Commissioner
  • Embassy, consulate, high commission
  • Lawyer or solicitor
  • Accountant
  • Bank
  • Garda√≠

Please provide these documents to our offices before we can commence the drafting of the Company Secretarial documentation.

Business Identification Requirements

As a government-regulated company formation agency, we are obligated to adhere to Anti-Money Laundering Regulations (AML). Government regulations mandate that we obtain two forms of identification from our clients during the company registration process.

AML ID proof is a compulsory requirement for the purchase of ongoing services, such as a registered office, company secretary, or business address service.

Our goal is to streamline this process for our clients, minimizing inconvenience. We kindly request that you provide two forms of identification documents, which can be chosen from the options listed below. Please note that the submission of identification documents is a necessary step to proceed with your company formation application.

What Types of Identification Are Accepted for Business Registration?

We are mandated to collect two types of identification: proof of name and proof of address:

Proof of Name (Please submit one of the following):

1. Copy of the current passport (must not be expired).
2. Current UK or EEA photocard driving license.
3. Full old-style driving license.
4. National identity card with the applicant’s name and photograph.
5. Residence permit issued by the Home Office to EEA nationals.
6. Photographic registration cards for self-employed individuals in the construction industry.
7. EEA member state identity card.

Proof of Address (Please submit one of the following):

1. Utility bill (gas, electric, or water bill issued within the last three months).
2. Council tax bill for the current council tax year.
3. Bank statement (or Building Society/Credit Union statement).
4. Mortgage statement from a recognized lender issued for the last full year.
5. HMRC self-assessment or tax demand letter.
6. NHS medical card.
7. Tenancy agreement for the current year or council/housing association rent card.
8. Benefit book or original notification letter from the benefits agency (only if not used as name proof).
9. Electoral registry entry.

Who Is Required to Provide Identification?

Identification documents must be provided by the following individuals/entities:

  • All persons listed as directors.
  • All individuals holding 25% or more of the voting shares.
  • The person placing the order (if not named as a director or shareholder).
  • In the case of corporate entities serving as directors or shareholders, the same procedure applies to each entity to identify the controlling individuals.

How to Submit ID Documents?

After submitting your company formation application, you will receive an email invitation from IDPAL (our third-party partner) to complete your online ID verification.
To complete your ID verification online, you will need to upload one or two ID documents and one address-proof document, along with a selfie photograph.
The uploaded documents will be reviewed, and if necessary, we will contact you for additional information.
What If You Cannot Use IDPAL?
If you are unable to use IDPAL or upload documents through IDPAL, you have the option to email certified copies of your documents to us.
For customers based in the UK or EU, the documents can be certified (handwritten and signed) by a registered accountant, lawyer, or medical doctor, attesting to their verification and authenticity.
For customers outside the EU, we will require notarized ID and address proof documents.

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