Block Capital UAB KYC Policy

Table of contents

1. Purpose

2. Customer information

2.1 Identifying Clients

3. KYC Tools

4. Onboarding procedure

4.1 Individuals

4.2 Corporates

4.2.1 Legal Representatives

4.2.2 Entity Signatory Information

4.2.3 Entity Beneficial Owners

5. Shell banks

6. Customer screening

7. Termination of business relationships with the customer

1. Purpose

This policy sets out the guidelines to be followed by Block Capital UAB. Our KYC policy aims to protect our company and customers from financial crimes like money laundering and fraud.

Our KYC policy outlines the procedures and requirements that we follow to verify the identity of our customers, including the collection of personal information, including but not limited to, such as name, address, date of birth, and identification documents.

KYC is a critical component of our overall risk management framework, and it enables us to establish the identity of our customers, monitor their transactions, and identify any suspicious activity. By implementing a robust KYC policy, we can reduce the risk of our platform being used for illegal activities, safeguard our reputation, and maintain the trust of our customers.

2. Customer information

Prior to entering a relationship with a client, the company collects the following information in an onboarding form:


  • Full name;
  • Date of Birth;
  • Personal Code (if assigned);
  • Residential address;
  • Nationality;
  • Occupation;
  • Purpose of the business relationship;
  • Description of the source of funds;
  • Description of the source of wealth;
  • ID, Driving Licence or Passport Number;
  • Tax identification number;
  • Acknowledgment of reading and understanding T&C;
  • Confirmation that provided data is correct.

Corporates (clients and business partners):

  • Entity detail Information (name, contact information, code);
  • Business Location information (registered and business address);
  • Legal representatives (e.g. directors) (full name, personal code or date of birth, nationality);
  • Entity signatory information;
  • Entity industry;
  • Legal form;
  • Purpose of the business relationship;
  • Description of the source of funds;
  • Description of the source of wealth;
  • Tax identification number;
  • Entity Beneficial Owners;
  • Annual turnover.

The verification of the information will be carried out either by viewing documentation from the client or via electronic checks.

Electronic checks will include the client’s full name, address, personal code and date of birth from the document and will be carried out by a provider who is registered with the Information Commissioner’s Office, use a range of positive information sources, can access negative information sources and has a transparent process.

2.1 Identifying clients

Whenever the company receives supporting documents related to a new client’s identity, the company needs to be completely satisfied the hat client demonstrates the existence as a real natural or legal person and that they are indeed whom they say they are. Although the Company will at times rely on third-party sources as part of its fact-checking procedure when onboarding clients, the Company bears ultimate legal responsibility for the verification being satisfactory.

Where the identification submitted is incomplete, inaccurate or otherwise insufficient, the company cannot proceed with opening an account for the client submitting such identification.

In more serious cases where money laundering, identity fraud or other crimes are suspected as opposed to simple carelessness or misunderstanding, the MLRO must inform the Lithuanian FCIS (FNTT).

3. KYC Tools

KYC means „Know Your Customer“ and sometimes „Know Your Client“. KYC or KYC check is the mandatory process of identifying and verifying the client’s identity when opening an account and periodically over time. In an increasingly global economy, financial institutions are more vulnerable to illicit criminal activities. Know Your Customer (KYC) standards are designed to protect financial institutions against fraud, corruption, money laundering and terrorist financing.

Block Capital UAB uses KYC tools (such as Veriff) which is our identity verification service that compares a customer’s selfie image with their ID document scan. We utilise market-leading facial recognition algorithms and a proprietary engine to indicate whether it’s the same person on both documents.

Veriff also helps us to screen individuals and companies against our global sanctions, watchlists, adverse media, and politically exposed persons (PEPs) database. Veriff enables us to check whether a given individual or company is the subject of international or local sanctions, has been banned or barred by a competent authority, or has been mentioned adversely by trusted media outlets.

4. Onboarding procedure

4.1 Individuals

Individuals will go through the Veriff system‘s process. Veriff is the Electronic Identity Document Verification service provider (EIDV). EIDV checks are as follows:

  • Veriff collects data input from the client;
  • Veriff process identification document for this check (i.e. Passport, Driving Licence, or National ID card);
  • Veriff confirms document authenticity through advanced security checks;
  • Veriff requests real-time selfie to validate the true likeness of the customer versus the ID document.

Identification documents and a selfie are recorded in the same real-time video session.

Veriff will check the following security features which must pass in order for the customer to


ID document:

  • Data comparison;
  • Data consistency;
  • Data validation;
  • Compromised document;
  • Image Integrity;
  • Age validation;
  • Visual authenticity.

Facial similarity:

  • Visual authenticity;
  • Image Integrity;
  • Face comparison.

Proof of address:

  • Equifax database;
  • Concentrix database.

4.2 Corporates

Corporates go through manual identification. Corporates will need to provide named documents (Where applicable documents must be less than 12 months old):

Company documents:

1. Incorporation documents or

2. Annual Returns or

3. Certificate of Good Standing.

Ownership documents:

1. Annual Returns or

2. Ownership structure or

3. Share Register extract or

4. Transparency registers for or

5. If none of the above is available, an org chart, certified and confirming all shareholders with

25%+ shareholding or to confirm the company is a subsidiary of a listed company.

4.2.1 Legal Representatives

The company will verify the identity of at least one director. The individual must pass the electronic verification checks in line with 4.1 or provide proof of identity and proof of address.

Proof of identity:

1. Current signed valid passport, or

2. Valid national identity card, or

3. Current photocard driving license complying with Directive 2006/126/EB of the European Parliament and the Council.

Proof of address:

1. Utility bill dated within the last 3 months, or

2. Current driving license (cannot be used for both proof of identity and proof of address), or

3. Bank statement dated within the last 3 months.

4.2.2 Entity Signatory Information

The signatory must pass the electronic verification checks or provide proof of identity and proof of address. (Only where the signatory is not the director or a beneficial owner).

The firm will collect evidence that the signatory is authorised to act on behalf of the firm.

Acceptable documents to confirm all individuals with Signing authority:

1. Company signatory list;

2. Board Resolution.

4.2.3 Entity Beneficial Owners

All individual beneficial owners (individuals who own or control over 10% of its shares or voting rights) must pass the electronic verification checks or Provide proof of Identity and address (in line with 4.2.1 This is applicable (but not limited to):

  • Limited Companies;
  • LLPs;
  • Beneficiaries, Settlors, controllers or class of persons where no individual for Trusts;
  • For Partnerships this refers to the Partners who own or control over 25% of its shares or voting rights.

5. Shell banks

Block Capital UAB prohibits the opening and keeping (and dealing with) of accounts of financial institutions operating without the required authorisation or license. Block Capital UAB further prohibits any dealings with Shell Banks or businesses that provide services to shell banks.

6. Customer screening

The company will perform Sanctions, PEP, Monitored lists and Adverse media checks. The customer will be screened against applicable lists in conjunction with their EIDV check by Veriff.

Veriff will screen the customer‘s name against:

  • Monitored Lists;
  • Adverse media;
  • Sanction;
  • Politically exposed person.

7. Termination of business relationships with the customer

Where the customer avoids or refuses to submit additional information to Block Capital UAB at its request and within the specified time limits, Block Capital UAB may, in accordance with internal policies and internal control procedures, refuse to execute monetary operations or transactions and terminate the transactions or business relationship with the customer.