BankinKYC

IND-1.2.0-draft · KYB-1.4.0-draft

Methodology

Each factor is scored 0–100 from configured rules. The overall score is R = Σ wᵢ·sᵢ. Weights and thresholds are BankinKYC product settings — they are not prescribed by the EBA or FATF and remain subject to validation by a qualified AML reviewer.

Factor weights

FactorIndividualCompany
Geographical exposure25%20%
Customer profile15%20%
Funds and wealth20%15%
Transactions and products20%20%
PEP and other exposure15%10%
Delivery channel5%0%
Ownership / control0%15%

Risk bands

  • 0–29 Low — Generally lower inherent risk indicators. Ordinary due diligence may still be necessary.
  • 30–59 Medium — Additional clarification or supporting information may be appropriate.
  • 60–100 High — Material risk factors that may warrant enhanced due diligence.

Override rules

These set a status of “Further verification recommended” rather than only adding points.

  • Ownership / control transparency concern — identify the ultimate owners and controllers, document the chain and explain any opaque arrangements.
  • Material inconsistency or unclear rationale — clarification is required; no final Low rating can be given.
  • Business authorisation needs verification — confirm the required licence, its validity and coverage.
  • PEP indicator — a bank is required to apply enhanced due diligence, including senior management approval and source-of-wealth checks. This does not imply wrongdoing.
  • High-risk third-country connection — the specific nature of the connection will be assessed and enhanced due diligence obligations may apply.
  • Possible sanctions exposure — separate verification is required. A score cannot resolve this.
  • Unexplained material source of funds — additional information is required.
  • Incomplete or unconfirmed answers — no final Low rating can be given.

Company KYB rules

The company model uses its own weights and questionnaire. Geography takes the highest connection across incorporation, operations, ownership and management without counting the same country twice. Ownership considers both ultimate ownership and control through other means. Delivery-channel points sit within the customer profile factor and remain visible in report explanations.

Indirect economic ownership multiplies the share percentages along each chain; separate paths to the same person are added together. For example, 60% of a holding entity that owns 80% of the assessed company gives 48% indirect ownership. Direct shares are added to the indirect total. No percentage automatically establishes or excludes beneficial-owner status: control through other means is recorded separately. Every entity must have 100% of its shares accounted for; gaps, invalid totals and circular ownership require clarification and prevent a final Low assessment. Circular structures are not calculated by this tool.

Company PEP answers of Yes or Unsure require named declarations, company roles and the relevant public function and country. Family and close-associate declarations also require the connected PEP's name and the relationship. Missing details make the report provisional. Names and ownership calculations add no extra risk points and never constitute screening; C17 supplies the PEP indicator once. Personal names remain in the browser tab and locally generated PDF.

Year established, legal form, turnover and relationship purpose provide context without points. When the company is represented by an external service provider or another person whose authority is unclear, the representative must be named. Missing answers, invalid years and declared material inconsistencies make the score provisional; no final Low rating is issued. Country tiers and all answer points are illustrative product settings requiring qualified AML review.

Company answer points and review indicators

C01 · In which country is the company incorporated?

Geographical exposure · EBA/GL/2021/02 §2.11–2.15 (geographical risk)

C02 · What is the company's legal form?

Context / validation only

  • Private limited company — 0 points
  • Public limited company — 0 points
  • Partnership — 0 points
  • Sole trader — 0 points
  • Non-profit / foundation — 0 points
  • Trust / similar arrangement — 0 points
  • Other — 0 points

C02_other · Please describe "Other" for: What is the company's legal form?

Context / validation only · Conditional follow-up

C03 · In which year was the company established?

Context / validation only

C04 · What is the principal operating country?

Geographical exposure · EBA/GL/2021/02 §2.11–2.15 (geographical risk)

C05 · What is the company's main industry?

Customer profile · EBA/GL/2021/02 §2.3–2.10 (customer risk)

  • General office / services — 0 points
  • Public sector — 5 points
  • Healthcare / education — 0 points
  • Technology / engineering — 0 points
  • Financial services — 10 points
  • Real estate — 30 points
  • Cash-intensive retail / hospitality — 30 points
  • Gambling — 45 points
  • Precious metals, art or luxury goods — 40 points
  • Crypto-asset services — 35 points
  • Arms / defence — 45 points
  • Other — 10 points

C05_other · Please describe "Other" for: What is the company's main industry?

Context / validation only · Conditional follow-up · EBA/GL/2021/02 §2.3–2.10 (customer risk)

C05b · Can you explain the business activity and its risk controls?

Context / validation only · Conditional follow-up · EBA/GL/2021/02 §2.3–2.10 (customer risk)

  • Yes — 0 points
  • Partly — 0 points
  • No — 0 points · INCONSISTENT

C06 · What products or services does the company provide?

Context / validation only

  • Physical goods — 0 points
  • Professional / business services — 0 points
  • Software / digital products — 0 points
  • Financial / payment services — 0 points
  • Property / investment activities — 0 points
  • Other — 0 points

C06_other · Please describe "Other" for: What products or services does the company provide?

Context / validation only · Conditional follow-up

C07 · Who are the main customers?

Context / validation only

  • Individuals — 0 points
  • Businesses — 0 points
  • Public institutions — 0 points
  • Intermediaries / agents — 0 points
  • Other — 0 points

C07_other · Please describe "Other" for: Who are the main customers?

Context / validation only · Conditional follow-up

C08 · Does the company carry out an activity requiring a licence or registration?

Context / validation only

  • No — 0 points
  • Yes — 0 points
  • Unsure — 0 points · LICENCE_REVIEW

C09 · What is the status of the required licence or registration?

Customer profile · Conditional follow-up · EBA/GL/2021/02 §2.3–2.10 (customer risk)

  • Valid and covers the activity — 0 points
  • Application pending — 20 points · LICENCE_REVIEW
  • Missing / expired / suspended — 50 points · LICENCE_REVIEW
  • Unsure — 25 points · LICENCE_REVIEW

C10 · What best describes the ownership?

Ownership / control · FATF Recommendation 24 (beneficial ownership transparency)

  • Directly owned by individuals — 0 points
  • Privately owned corporate group — 10 points
  • Listed company — 0 points
  • State-owned — 0 points
  • Trust / foundation structure — 20 points
  • Other / uncertain — 25 points

C10b · On which regulated market or exchange is the company (or its parent) listed, and under which ticker / ISIN?

Context / validation only · Conditional follow-up · FATF Recommendation 24 (beneficial ownership transparency)

C11 · How many corporate ownership layers sit above the company?

Ownership / control · FATF Recommendation 24 (beneficial ownership transparency)

  • None — direct ownership — 0 points
  • One — 5 points
  • Two — 15 points
  • Three or more — 30 points
  • Unknown — 40 points · OWNERSHIP_OPAQUE

C11b · Is there a documented economic or legal reason for the ownership structure?

Ownership / control · Conditional follow-up · FATF Recommendation 24 (beneficial ownership transparency)

  • Yes — 0 points
  • Partly — 15 points
  • No / unknown — 30 points · OWNERSHIP_OPAQUE

C12 · In which countries do the beneficial owners reside?

Geographical exposure · EBA/GL/2021/02 §2.11–2.15 (geographical risk)

C13 · Can all ultimate beneficial owners be identified and documented?

Ownership / control · FATF Recommendation 24 (beneficial ownership transparency)

  • Yes — 0 points
  • Partly / exemption claimed — 30 points · OWNERSHIP_OPAQUE
  • No — 60 points · OWNERSHIP_OPAQUE

C13b · Have you identified persons exercising ultimate control through other means?

Ownership / control · FATF Recommendation 24 (beneficial ownership transparency)

  • Yes — identified or documented none — 0 points
  • Not yet / unsure — 30 points · OWNERSHIP_OPAQUE

C14 · Are there nominee or bearer-share arrangements?

Ownership / control · FATF Recommendation 24 (beneficial ownership transparency)

  • No — 0 points
  • Nominee arrangements — 25 points · OWNERSHIP_OPAQUE
  • Bearer shares — 50 points · OWNERSHIP_OPAQUE
  • Unsure — 25 points · OWNERSHIP_OPAQUE

C14b · Describe the bearer-share arrangement: how many bearer shares exist, who holds them, and whether they are immobilised with a custodian or registered.

Context / validation only · Conditional follow-up · FATF Recommendation 24 (beneficial ownership transparency)

C14c · Describe the nominee arrangement: who acts as nominee and for whom (the underlying principal).

Context / validation only · Conditional follow-up · FATF Recommendation 24 (beneficial ownership transparency)

C15 · In which countries do the directors reside?

Geographical exposure · EBA/GL/2021/02 §2.11–2.15 (geographical risk)

C16 · Where is the company actually managed?

Geographical exposure · EBA/GL/2021/02 §2.11–2.15 (geographical risk)

C17 · Are any beneficial owners, controllers or directors PEPs, or family members / close associates of PEPs?

PEP and other exposure · FATF Recommendation 12 (PEPs)

  • No — 0 points
  • Yes — 60 points · PEP
  • Unsure — 25 points · PEP

C18 · Are you aware of sanctions restrictions affecting the company, its owners, controllers or directors?

PEP and other exposure · EU restrictive measures (Art. 215 TFEU)

  • No — 0 points
  • Yes — 80 points · SANCTIONS
  • Unsure — 30 points · SANCTIONS

C18b · Describe the sanctions concern: which person or entity, which sanctions list or regime (e.g. EU, UN, OFAC, UK), and the nature of the link.

Context / validation only · Conditional follow-up · EU restrictive measures (Art. 215 TFEU)

C19 · What is the annual turnover?

Context / validation only

  • Pre-revenue — 0 points
  • Under €100,000 — 0 points
  • €100,000 – €1 million — 0 points
  • €1 million – €10 million — 0 points
  • Over €10 million — 0 points

C20 · What is the main source of funds for the account?

Funds and wealth · FATF Recommendation 10 (CDD)

  • Business revenue — 0 points
  • Investment income — 10 points
  • Bank / institutional loan — 5 points
  • Shareholder funding — 15 points
  • Grants / donations — 15 points
  • Other — 30 points

C20_other · Please describe "Other" for: What is the main source of funds for the account?

Context / validation only · Conditional follow-up · FATF Recommendation 10 (CDD)

C21 · How was the business capital originally obtained?

Funds and wealth · FATF Recommendation 10 (CDD)

  • Retained earnings — 0 points
  • Founders' savings — 5 points
  • External investors — 15 points
  • Loans — 10 points
  • Asset sale — 10 points
  • Gifts / donations — 25 points
  • Other / unknown — 35 points

C21_other · Please describe "Other" for: How was the business capital originally obtained?

Context / validation only · Conditional follow-up · FATF Recommendation 10 (CDD)

C20b · Can you explain and document significant funds and the origin of capital?

Funds and wealth · FATF Recommendation 10 (CDD)

  • Yes — 0 points
  • Partly — 25 points
  • No — 50 points · SOF_UNEXPLAINED

C22 · What monthly transaction volume do you expect?

Transactions and products · EBA/GL/2021/02 §2.16–2.19 (products, services, transactions)

  • Under €10,000 — 0 points
  • €10,000 – €100,000 — 10 points
  • €100,000 – €1 million — 25 points
  • €1 million – €10 million — 40 points
  • Over €10 million — 55 points

C22b · Are the expected flows consistent with turnover, capital and the business purpose?

Context / validation only · FATF Recommendation 10 (CDD)

  • Yes — 0 points
  • Different, but documented rationale — 0 points
  • No / cannot explain — 0 points · INCONSISTENT

C23 · How cash-intensive is the business?

Transactions and products · EBA/GL/2021/02 §2.16–2.19 (products, services, transactions)

  • No cash — 0 points
  • Occasional cash — 10 points
  • Frequent / substantial cash — 35 points

C24 · Will the company send or receive international payments?

Transactions and products · EBA/GL/2021/02 §2.16–2.19 (products, services, transactions)

  • No — 0 points
  • Yes — 10 points

C25 · Which countries will be involved in the payments?

Geographical exposure · Conditional follow-up · EBA/GL/2021/02 §2.11–2.15 (geographical risk)

C25b · What is the main purpose of international payments?

Context / validation only · Conditional follow-up

  • Goods / services — 0 points
  • Group treasury / investment — 0 points
  • Payroll / operating costs — 0 points
  • Other / unclear — 0 points · INCONSISTENT

C25b_other · Please describe "Other" for: What is the main purpose of international payments?

Context / validation only · Conditional follow-up

C26 · Will the company make or receive payments on behalf of third parties?

Transactions and products · FATF Recommendation 10 (CDD)

  • No — 0 points
  • Yes — 30 points

C26b · Can you identify the third parties and document the reason and authority for their payments?

Funds and wealth · Conditional follow-up · FATF Recommendation 10 (CDD)

  • Yes — 0 points
  • Partly — 15 points
  • No — 35 points · SOF_UNEXPLAINED

C27 · Will the company have crypto-asset exposure?

Transactions and products · EBA/GL/2021/02 §2.16–2.19 (products, services, transactions)

  • No — 0 points
  • Occasional — 10 points
  • Regular — 25 points

C28 · What is the purpose of the banking relationship?

Context / validation only

  • Day-to-day business operations — 0 points
  • Savings / treasury — 0 points
  • Investment — 0 points
  • Trade finance — 0 points
  • Other — 0 points

C28_other · Please describe "Other" for: What is the purpose of the banking relationship?

Context / validation only · Conditional follow-up

C29 · Which banking products do you expect to use?

Transactions and products · EBA/GL/2021/02 §2.16–2.19 (products, services, transactions)

  • Current account / payments — 0 points
  • Deposits — 0 points
  • Loans / credit — 5 points
  • Trade finance — 15 points
  • Correspondent / payable-through services — 35 points
  • Other — 15 points

C29_other · Please describe "Other" for: Which banking products do you expect to use?

Context / validation only · Conditional follow-up · EBA/GL/2021/02 §2.16–2.19 (products, services, transactions)

C29b · How will the company open the banking relationship?

Customer profile · EBA/GL/2021/02 §2.20–2.22 (delivery channel)

  • In person at a branch — 0 points
  • Online with qualified eID — 10 points
  • Online without eID — 30 points

C31 · Who is the authorised representative of the company for this assessment and the banking relationship?

Customer profile · EBA/GL/2021/02 §2.20–2.22 (delivery channel)

  • Director or board member — 0 points
  • Shareholder or beneficial owner — 0 points
  • Authorised employee with power of attorney — 0 points
  • External service provider or adviser — 10 points
  • Other or unsure — 10 points

C31b · Name the representative and describe their role and authority in the company.

Context / validation only · Conditional follow-up · EBA/GL/2021/02 §2.20–2.22 (delivery channel)

C34 · Do the company have, or has it had in the last 5 years, accounts or a relationship with other banks or payment institutions in the EU?

PEP and other exposure · FATF Recommendation 10 (CDD)

  • No — 0 points
  • Yes, currently — 0 points
  • Yes, closed at the company’s request — 0 points
  • Yes, the institution ended the relationship — 15 points

C34b · Name the institution(s) and country, and, if the relationship ended, why.

Context / validation only · Conditional follow-up · FATF Recommendation 10 (CDD)

C30 · Are the company answers complete and accurate to the best of your knowledge?

Context / validation only

Design principles

Both reports explain answer-specific document preparation and why Compliance may need more evidence. The individual report covers identity, funds / wealth, PEP connections, geography, sanctions, large flows, international / third-party payments, cash / crypto and remote onboarding, as relevant. I19 records past routine requests; Examples follow EU / FATF principles; they are not legal document lists. I24 / C34 record relationships with other EU banks; where one exists or ended, the institution must be named. A request deadline is set by the bank, not by this app. Sanctions are a separate legal regime. High risk, PEP status and a country connection alone are not automatic prohibitions.

  • The same geographic connection (residence, citizenship, income) is counted once — the highest tier applies.
  • Context questions (e.g. who you transact for) shape follow-ups but carry no points.
  • Prior document requests, international payments and legitimate crypto use are context, not proof of anything.
  • Country tiers are illustrative and must be checked against the current EU high-risk third-country list.
  • The current regime (Directive (EU) 2015/849) applies until Regulation (EU) 2024/1624 becomes applicable on 10 July 2027.
  • No answers are stored or sent. The PDF is produced by your browser.

References