KYB Customer Identification Procedures (CIP)

About iComply

iComply’s platform enables regulated entities to perform risk-based onboarding, verification, and monitoring of legal entities in accordance with international Know Your Business (KYB) and Customer Due Diligence (CDD) requirements. Configurable workflows and encrypted KYB portals ensure jurisdictional compliance in over 195 ISO-3166 countries.

All data collection and processing leverages iComply’s privacy-by-design infrastructure, supporting local data residency, auditability, and integration with preferred data providers. Legal entity onboarding is tightly linked to the identification of authorized natural persons and enables full ownership and control discovery.

 

Supported KYB Workflows

iComply’s KYB process includes multiple configurable modules, each of which can be triggered automatically or manually, based on jurisdictional workflows, internal risk policies, or onboarding triggers.

Modules include:

• Legal Entity Onboarding

• Legal Entity Verification

• UBO and Control Person Discovery

• Nominee and Third-Party Authorization

• Enhanced Due Diligence (EDD)

• Supporting Document Collection

• Attorney and Board Confirmation

• Entity Record Search and Monitoring

 

Legal Entity Onboarding

A natural person must first be authenticated through the Natural Person CIP process before initiating onboarding for a legal entity. This individual can then onboard one or more legal entities through:

• GLEIF Integration: Search and autofill via Global Legal Entity Identifier (GLEI). Users can confirm or update details and submit entity data for review.

• Manual Entry: Portal users can input all entity information directly. Submissions appear in the KYC dashboard for review and verification.

• Registry & Data Search (Optional): For advanced configurations, iComply supports integration with public registries and commercial providers. These are only activated upon request to enhance automation and accuracy.

 

Legal Entity Verification

Entity identity is verified through documents, registry data, or optional data enrichment. Verification may include:

• Proof of incorporation or business license

• Registered business address

• Directors and authorized officers

• Matching nominee to listed control persons

If GLEI data is available and current, straight-through verification can occur. Otherwise, a verification task is generated in the dashboard for compliance officer review.

 

Process Description for Legal Entities

 

Legal Entity Onboarding

Once a portal user has been successfully identified, they can complete Legal Entity Onboarding as a verified user. While it is possible to configure the system to support the onboarding of Legal Entities with unverified users, it is not recommended as this tends to lead to higher rates of fraud, bad data, and increased costs.

iComply supports three methods of onboarding legal entities: GLEI, manual entry, and corporate record search through a combination of open, public, and private proprietary data sources. The customer-facing LE Portal can support the GLEI or manual entry methods depending on the system configuration. 

 

Global Legal Entity Identification Foundation - GLEIF

Where a Global Legal Entity Identifier (GLEI) process is used, the portal user can search by the legal entity name or GLEI numbers. The portal user can select their company from the search results, review legal entity details, and provide updated key information such as address and contact information. Once submitted through the LE Portal, the legal entity data will be visible in the KYC Dashboard. 

Companies can manage their LEI through iComply partners such as Bloomberg LEI. https://lei.bloomberg.com/

 

Manual Entry

When using the manual entry method, a portal user will be able to enter legal entity information, and review, and confirm their submission. No validation is performed at the submission stage. Once submitted through the portal, the legal entity data will be visible in the KYC Dashboard. In the KYC Dashboard, users may review, update, approve, or reject the submission, or initiate a Legal Entity Verification request on the legal entity.

 

Open, Public, and Proprietary Data Sources

When using the entity search tool to Add a Legal Entity, a new search is run to analyze billions of data points -  including search engine data, blogs, news, social media, watchlists, ownership records, registries, and other entity data - in real-time. Each search consolidates potential results into entity profiles for further disposition, investigation, and reporting.

 

Legal Entity Verification

Identity verification on legal entities can be completed almost instantly when sufficient data is available - such as when the legal entity has a valid GLEI file. For private companies, the GLEI data is often stale, or may not exist at all. In these cases, an Investigation into the company can be initiated to search open, public, and proprietary data sources to disposition the identity of the legal entity, documents, and related parties.

 

Legal Entity Investigation

Investigations can include tasks such as authenticating authorized contacts, directors & officers, addresses, proof of incorporation, and proof of residency. A search for a Legal Entity can be submitted in the dashboard, through workflow automation, or via the API.

 

Legal Entity Addresses

Address verification may require supporting documentation, biometric authentication, and manual processing. Authorized representatives of a legal entity can update their primary and secondary addresses through the Legal Entity Portal. 

Address information can be validated against third-party data sources or automated processing. In exceptions where straight-through processing is not possible, the Issue will appear on the Legal Entity’s profile for manual review and approval.

 

Supporting Documents and Address Validation

Entities can upload:

• Articles of incorporation

• Shareholder registers

• Business licenses

• Financial statements

• Proof of address (e.g., lease, utility bills)

Address validation may include biometric authentication, automated document parsing, or external lookup (if available). Where automated checks fail, issues are flagged for manual review.

 

Enhanced Due Diligence (EDD)

EDD workflows may be triggered by:

• High-risk jurisdictions

• PEP or sanctions screening matches

• Complex or opaque ownership structures

• Manual compliance officer flagging

EDD steps can include:

• Independent verification by legal counsel or board

• Additional financial documentation

• Regulatory filings

• Source of funds declarations

All supporting documents are retained in the platform with full audit logs.

 

Beneficial Ownership

Entity relationships can be created and linked in the Legal Entity profile to show beneficiaries above set thresholds of ownership or control. Enhanced Due Diligence workflows can be configured to accept Supporting Documents through the Legal Entity Portal. 

A Beneficial Ownership search for related entity requests will identify potential beneficiaries through GLEI, open, public, and proprietary sources.

 

UBO and Ultimate Beneficial Ownership Discovery

The platform supports nested entity structures, allowing compliance teams to:

• Define thresholds for beneficial ownership (e.g., 25%+ control)

• Collect declarations or supporting documentation

• Conduct recursive reviews when UBOs are legal entities (Ultimate Beneficial Ownership)

• Link entity relationships within the Legal Entity Profile

Beneficiaries can be discovered through declarative input, GLEI data, or (optionally) through registry lookups and commercial datasets.

In many cases, the list of Beneficial Owners can include legal entities, such as companies, trusts, organizations, etc.. Ultimate Beneficial Ownership reviews can be managed in the Legal Entity profile by initiating Beneficial Ownership reviews on all entities listed that are not Natural Persons. 

 

Nominee Authorization and Role Verification

Once a natural person is verified, they may act as a nominee, authorized signatory, director, officer, or legal counsel. Nominee authorization workflows confirm alignment with entity roles through:

• Director/Officer matching

• Documented authority (e.g., power of attorney, board resolution)

• Manual or automated issue generation for exceptions

Nominee authorizations can be performed by matching the identity of the user to a primary contact, director, officer, or authorized representative of the legal entity. Straight-through processing can be configured but exceptions will still appear in the KYC Dashboard as Issues. Enhanced workflows can trigger Supporting Documents and Enhanced Due Diligence requests to the Legal Entity Portal while the user is still in session. 

 

Process Description for Verifying Third Parties

 

Third-Party Confirmation & Authorization

In some jurisdictions, lawyers, notaries, or licensed agents may be required to submit onboarding data. iComply enables:

• Authorization tracking

• Document review and confirmation by counsel or board

• Role-based access to KYB Portal workflows

• Logging of third-party involvement for audit purposes

Legal counsel, nominees, and powers of attorney are examples of third-party representatives that can be Authorized to submit information on behalf of a legal entity. 

In jurisdictions where straight-through processing is not possible, whether due to regulation or market availability, third-party representatives such as legal counsel become an integral part of the KYC customer lifecycle. 

Configure Enhanced Due Diligence workflows to include a review by the legal entity’s legal counsel or board of directors. Authorized representatives can review and confirm the information submitted by their clients for:

• Beneficial Ownership
• Regulatory Reporting
• Financial Records
• Board Resolutions
• Annual Filings
• Tax Reporting

 

Regulatory Alignment

iComply’s KYB procedures align with global standards: