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Application guidance Unrestricted distribution July 2013 Intermediaries - PLC

Barclays pitchbook template (for GR&I, IID clients and ... · PDF fileApplication guidance 2 1. The guidance notes comprise the following important sections: 1) Key information: A

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Page 1: Barclays pitchbook template (for GR&I, IID clients and ... · PDF fileApplication guidance 2 1. The guidance notes comprise the following important sections: 1) Key information: A

Application guidance

Unrestricted distribution

July 2013

Intermediaries - PLC

Page 2: Barclays pitchbook template (for GR&I, IID clients and ... · PDF fileApplication guidance 2 1. The guidance notes comprise the following important sections: 1) Key information: A

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CONTENTS

Purpose of the guide

Information checklist

Key information

Key documents

Document certification

Disclaimer

Page 3: Barclays pitchbook template (for GR&I, IID clients and ... · PDF fileApplication guidance 2 1. The guidance notes comprise the following important sections: 1) Key information: A

2 Application guidance

1. The guidance notes comprise the following important sections:

1) Key information: A checklist to provide guidance on level and extent of information required

in the account application. Examples from actual case studies are included to assist with the completion of the application to the standards required

2) Key documents: A checklist highlighting the additional/supporting documents for the various

types of entities for which an account may be required

3) Document certification: An explanation of how primary and secondary verification documents should be certified, and who may certify these documents. Detailed

requirements are set out in section 5 – please take the time to read this as it will greatly reduce the chance of application delay or rejection

1. Purpose of the guide

The purpose of this guide is to provide general guidance on the information required to complete the account application form and the supporting documents required in order to meet our Client Due Diligence (CDD) standards. This should help to alleviate common errors and facilitate an efficient account opening experience. In certain cases, we may request additional information and/or documents to be provided at our discretion.

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This checklist should be used to ensure that the sections listed have been correctly completed and contain suitably detailed information. This will ensure that the application and account opening is processed in a timely manner.

2. Information checklist

Checklist

Purpose/intended nature of business (Page 2 of application form)

Source of funds (Page 3 of application form)

Source of wealth (Page 3 of application form)

Description of activity

(Page 4 of application form)

Countries of trade and activity

Trading counterparties (if applicable)

Estimated annual business turnover

Estimated annual account turnover

Estimated number of payments per annum and average value per payment Estimated number of credits per annum and average value per credit

Structure chart (business ownership structure with more than three tiers) (Page 5 of application form)

Application guidance

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Hints and tips for providing accurate and consistent information

This section explains how to complete the various sections of the account application form to ensure that sufficiently detailed information is provided to meet our Client Due Diligence requirements. The examples that follow have been created using actual case studies.

3. Section 1: Key information

Application guidance Application guidance

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3.1 Purpose/intended nature of business A detailed description of the nature and intent of the business purpose should be provided. Information

regarding Source of Funds (3.2) and Description of Activity (3.4) in the later sections of the application form should be consistent to the purpose/intended nature of business. It is important we understand the whole transaction chain in which the client is involved.

(Page 2 of account application)

Other examples of acceptable descriptions:

Company owns three residential properties in London. These are rented out to private tenants from whom rental income will be deposited to the account on a monthly basis.

The Trust has been set up on behalf of ABC Limited (ABC Limited a UK based civil engineering company) as an Employee Benefit Trust for its Employees

The Trust is set up on behalf of the Settlor. It is intended for the education and well being of his / her family. The assets held within the trust are an investment portfolio held with Barclays and rental income from a residential property in London.

Acceptable level of detail

Holding shares in Italian company 123 SRL. Underlying activity is in the field of Commercial Real Estate (warehouses) in Rome

Consultancy in real estate sector, client receives a finder’s fee for getting a buyer for residential property

Financial services – company introduces client to an Italian bank, and receives commission on number of introductions

The company owns, lets, buys and sells property, specialising in industrial use commercial property in UK, Channel Islands and France

Insufficient detail

Holding shares in Italian company – 123 SRL

Consultancy

Financial services

Investment in real estate

Application guidance

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The information required to explain the source of the initial and ongoing transactions that will be seen through the account i.e. a description of how the account will be used in future.

The description provided in this section should correlate to the purpose/intended nature of business (3.1).

3.2 Source of funds (Page 3 of account application)

Other examples of acceptable descriptions:

The client’s trust bank accounts were previously held at ABC Bank. The initial deposit of funds to the trust accounts will be from ABC Bank. The balance held at ABC Bank is an accumulation of investment income over a period time. The account will be used to receive further investment income in the form of dividends and capital withdrawals.

The client has sold shares in a company called ABC Limited. The proceeds from the sales of shares will paid in as the initial deposit of funds, and is being paid from XYZ Bank Switzerland. The account will be used to hold these proceeds until further investment decisions are made.

Funds will be generated from clients who will pay fees/subscriptions via a secure/reputable credit card company.

Payment will be made from ABC Ltd, the underlying company of the trust, who banks with XYZ Bank Jersey. The payment represents a dividend distribution from this company. The account will be used for similar receipts in future.

Insufficient detail

From counterparty – ABC Ltd

Consultancy

Investment in real estate

Acceptable detail

Payment from bank account with ABC Ltd. Balance is accumulation of surplus trade income in the business. Ongoing turnover on the account will stem from normal trading activities .

From the first invoice relating to consultancy services provided to ABC Ltd. Further turnover through the account will be from the same source.

The proceeds from the sale of a property previously owned and recently sold by the client. Further turnover through the account will stem from rental income received and other property investment transactions.

Application guidance

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3.3 Source of wealth

A description of the activities that have generated the total net worth of a person/entity both within and outside of a relationship, i.e. those activities which have generated a client’s funds and property.

(Page 3 of account application)

A further example of an unacceptable statement for Source of Wealth would be: ‘Life Time Savings’

Life-time savings/investments of settlor/beneficial owner – Settlor/Beneficial owner is a senior consultant doctor with CBA Practice/hospital located in Glasgow, UK.

Sale of business – Client sold ABC Limited (a car dealer in Jersey). Please refer to the website www.abc.com for further details of this transaction.

Redundancy/large bonus payments – from previous employment as a London City Commodities trader.

Inheritance – from death of client’s father who was the founder of ABC Limited, a property development company in Rep. of Ireland.

Trading activity – The client has sold shares in a company called ABC Limited. The proceeds from the sale will be paid in as the initial deposit of funds from XYZ Bank Switzerland.

Acceptable detail

Wealth has been accumulated over many years of consultancy in field of gas and oil

Inheritance from recently deceased father, John Smith, who was the retired CFO for a large Turkish manufacturing company

Beneficial owner was a specialist in the real estate field for 20 years, and has accumulated wealth over this time

Insufficient detail

Consultancy

Inheritance, family will

Professional activities

Application guidance

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Countries of trade

It is important to list the main countries in, or with which, the company conducts (or plans to conduct) its business activities. Please remember to:

List all countries with estimated trade of 5%* or more of business turnover;

List approximate percentage of trade in/with each

For start up companies please list the countries in/with which business is intending to trade together with approximate percentages.

Estimated annual business turnover

Estimated annual account turnover

Estimated number of debits

Estimated number of credits

These fields must be completed as this information forms part of our Client Due Diligence requirements. This information does not have to be precise but we would expect a considered estimation; and should correlate to the purpose/intended nature of business

and source of funds information.

Trading counterparties

It is important to list the main counterparties with which the business is/will be trading. Please remember to:

List all known counterparties with estimated trade of 15%* or more of business turnover;

List approximate percentage of business with each

For start up companies - it is acceptable to state “not known at this stage”. We may ask for copy of first contract (or similar) when trading commences.

3.4 Description of activity

(Page 4 of account application)

A detailed breakdown of the countries and the counterparties with which the entity will trade. This information should correlate to the purpose/intended nature of business.

* Applicants in Cyprus need to supply a complete list of all countries and counterparties, regardless of percentage trade

Application guidance

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A structure chart for a business structured with three layers of ownership or more should be provided to allow us to understand the flow of funds. An example of an acceptable structure chart is provided below:

3.5 Complex structures (Page 5 of account application)

Application guidance

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Supplementary documents and information

This section provides general guidance about the additional documents that should be attached with an account application for each entity type. In certain cases, we may request additional documents to be provided at our discretion. Please note that the additional documents that need to be submitted will vary depending on your Client Due Diligence category – ‘Disclosed’ or ‘Fully Supported’. (If your delegation category is not known, please refer to your local Business Partner or Relationship Manager). The tables on the following pages will clarify which documents are required for each category. Where the requested documents are not available, please contact your Business Partner for further guidance. Where documents are ‘not required’ under the ‘Disclosed’ category, they need be retained in your records and you should be able to provide these documents on request. All supplementary documents provided should be certified. Please refer to the Document Certification (5) guide at the end of this section for further information and guidance. We may request additional information or documents following our risk assessment where cases have increased or high risk factors.

4. Section 2: Key documents

KEY: = Not required = Required

Notes: 1. Gibraltar: Introducers are required to provide an

Applicant Introduction Certificate (F1) 2. Cyprus: An additional list of entity specific

requirements for applicants in Cyprus is provided at the end of this section.

Application guidance

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4.1 Limited company (including LLC)

CDD documents required per level CDD requirements*

Document list Disclosed Fully Supported Direct**

Certificate of Incorporation

London London, Gibraltar, Guernsey

Jersey, Guernsey Jersey

IOM - Only required for companies incorporated outside of IOM, Jersey, Guernsey & UK

Certificate of Good Standing (conditional) Gibraltar

Jersey, Guernsey, IOM, London

Register of shareholders

Register of directors

(If shares held on nominee basis, a Certified Declaration of Trust/Nominee Agreement is required)

License (if applicable for Regulated Entity)

Passports (for all parties not known to Barclays) (Except IOM - )

Proof of address (e.g. utility bill) (not more than six months old)

Structure chart (where there 3 or more tiers between applicant and ultimate beneficial owner) Copies of financial accounts (where previous company trading has helped generate source of

wealth of the business)

* Please refer to your Relationship Manager or Business Partner if not known ** Clients introduced by a key business introducer but where the accounts will not be managed by the introducer.

Application guidance

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4.2 Trust

CDD documents required per level CDD requirements

Document list Disclosed Fully Supported Direct

Extract of Trust Deed or letter from Lawyer confirming :

Date and place of the trust establishment Settlor/trustee/protector/beneficiaries Purpose of Trust

(Except IOM - )

Passports (for all parties not known to Barclays) (Except IOM - )

Proof of address (e.g. utility bill) (not more than six months old)

Application guidance

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4.3 Foundation

CDD documents required per level CDD requirements

Document list Disclosed Fully Supported Direct

Foundation Articles/Charter

Foundation By Laws/Regulations

Proof of Foundation registration

Passports (for all parties not known to Barclays)

(Except IOM - )

Proof of address (e.g. utility bill) (not more than six months old)

Application guidance

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4.4 Quoted*

CDD documents required per level CDD requirements

Document list Disclosed Fully Supported Direct

Certificate of Incorporation

Structure chart (where the applicant is a majority owned and consolidated subsidiary of a public quoted company)

* Listed companies on Barclays recognised list of approved Stock Exchanges. For further information, please refer to your Relationship Manager or Business Partner.

Application guidance

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4.5 Sole trader

CDD documents required per level CDD requirements

Document list Disclosed Fully Supported Direct

Passports (for all parties not known to Barclays) (Except IOM - )

Proof of address (e.g. utility bill) (not more than six months old)

Application guidance

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4.6 Pension scheme

CDD documents required per level CDD requirements

Document list Disclosed Fully Supported Direct

Certificate of Approval

Extract of Trust Deed (if classified as a trust) (Except IOM - )

Passports* (for all parties not known to Barclays) (Except IOM - )

Proof of address* (e.g. utility bill) (not more than six months old)

* Only required for individuals who are the sponsoring employer or who have control over the scheme; and not required for the underlying employees.

Application guidance

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4.7 Investment Fund – Regulated/Unregulated

CDD documents required per level CDD requirements

Document list Disclosed Fully Supported Direct

Certificate of Incorporation or Partnership Agreement

Prospectus

Offering document

Listing documents

Passports* (for all parties not known to Barclays) (Except IOM - )

Proof of address* (e.g. utility bill) (not more than six months old)

* Only required for Unregulated Investment Funds.

Application guidance

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4.8 Partnership (including LLP)

CDD documents required per level CDD requirements

Document list Disclosed Fully Supported Direct

Partnership Deed of Partnership Agreement (if applicable)

Evidence of the appointment of a general partner (limited partners only)

Passports (for all parties not known to Barclays) (Except IOM - )

Proof of address (e.g. utility bill) (not more than six months old)

Application guidance

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4.9 Cyprus – additional requirements

Entity type Additional requirements

Limited company

Directors/Shareholders/Registered Address CV of the Underlying Beneficial Owner(s) (UBO) is required Certificate of Directors/Secretary

Trust

A letter from the Trustees (if an in house company of KBI-introducer) confirming all parties related to the trust confirming: Date and place of the trust establishment Settlor/trustee/protector/beneficiaries Purpose of Trust

Foundation

Board/council Member If a beneficiary is identified but has not yet received any distribution from the foundation i.e. is not vested then there is a

requirement to verify the identity Details of the Foundation Assets Identification of Founder/Board or council member/Beneficiaries (where established)

Quoted Certificate of directors/ registered address Passport and address verification for all signatories on the account

Provident Fund

Certificate of Registration Certificate of committee members of the provident fund Address verification for all committee members and signatories Rules of the Fund

Investment Fund

Identification of the fund manager Identification of all directors If the account is a Fund then passport copies and residential address verification for all directors is required. If the fund is not regulated in a jurisdiction which is approved by Barclays we need passport and proof of address of all

investors with 10% or more.

Partnership (including LLP)

Certificate of Registration/partners/registered address Passports (for all parties not known to Barclays) – General Partners, Limited Partners and signatories on the account

Application guidance

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5. Section 3: Document certification

Certification of primary verification documents (i.e. passports, drivers licenses, EU identity cards for all parties not known to Barclays) The certified copies of personal identity evidence should include the following details and wording by the certifier: Date Signature The name and position or capacity of the certifier must be clearly identifiable* Address and telephone number or email address where the certifier can be contacted Should confirm in writing that it is a true copy of the original(s) and that the certifier has seen the original document and the

photograph is of a true likeness Certification of secondary verification documents (Residential address verification for all parties not known to Barclays. Please note utility bills should be no more than six months old and we cannot accept mobile phone bills) The certified copies of personal identification evidence should include the following details of the certifier: Date Signature The name and position or capacity of the certifier must be clearly identifiable* Address and telephone number or email address where the certifier can be contacted * Certification may be undertaken by an employee of Barclays or another acceptable certifier such as: Government department Director of authorised credit or financial institution Director, company secretary or manager/authorised signatory of an counterparty assessed and approved by Barclays Director of trust company/fund manager approved by the local financial regulator Embassy, consulate or high commission officer in the country the document was issued Registered lawyer or attorney Accountant/actuary in a firm subject to professional regulation Notary public, a member of the judiciary, a senior civil servant or a serving police officer

Application guidance

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Disclaimer

This document has been issued and approved by Barclays Bank PLC. Although information in this document has been obtained from sources believed to be reliable, we do not represent or warrant its accuracy, and such information may be incomplete or condensed. This document does not constitute a prospectus, offer, invitation or solicitation to buy or sell securities and is not intended to provide the sole basis for any evaluation of the securities or any other instrument, which may be discussed in it. All estimates and opinions included in this document constitute our judgement as of the date of the document and may be subject to change without notice. This document is not a personal recommendation and you should consider whether you can rely upon any opinion or statement contained in this document without seeking further advice tailored for your own circumstances. This document is confidential and is being submitted to selected recipients only. It may not be reproduced or disclosed (in whole or in part) to any other person without our prior written permission. Law or regulation in certain countries may restrict the manner of distribution of this document and persons who come into possession of this document are required to inform themselves of and observe such restrictions. We or our affiliates may have acted upon or have made use of material in this document prior to its publication. You should seek advice concerning any impact this investment may have on your personal tax position from your own tax adviser.

Barclays offers wealth and investment management products and services to its clients through Barclays Bank PLC and its subsidiary companies. Barclays Bank PLC is registered in England and authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Registered No. 1026167. Registered Office: 1 Churchill Place, London E14 5HP.

© Barclays Bank PLC 20014. All rights reserved. Barclays Stockbrokers is a trading name of Barclays Bank PLC (Registered No. 1026167 Registered VAT No. 243 8522 62) which is a member of the London Stock Exchange and ISDX.

Item Ref: IBIM2137. March 2014

Application guidance