RIVEROS CORP NETWORK | Apostille de la Haya · Notary Public Center · Compliance Officers · USJurisdiction
RIVEROS CORP NETWORK | Apostille de la Haya · Notary Public Center · Compliance Officers · USJurisdiction
The procedure your company uses to identify who it is dealing with before accepting them as a client, partner or vendor. We run it to the US due diligence standard and deliver a documented file, with sources cited, that holds up to a regulator’s review.
KYC (Know Your Customer) is the set of procedures a company uses to identify a client, verify that the client is who they claim to be, understand where their funds come from and assess the money laundering risk they pose before entering into a business relationship.
It is not a form or a photocopy of a passport. It is a process with four components that regulators expect to see documented: identification, verification against independent sources, understanding of the business relationship and ongoing monitoring for as long as that relationship lasts.
In the United States its backbone is FinCEN’s Customer Due Diligence Final Rule (31 CFR 1010.230) and the customer identification program introduced by Section 326 of the USA PATRIOT Act. The FATF sets it out as an international standard in its Recommendation 10.
Who the person or entity is, with data that can be checked: name, date of birth, address and identification number.
Check that data against independent, reliable sources. A client’s word alone verifies nothing.
The purpose of the business relationship and the activity expected from it. Without that, there is no way to spot what is unusual.
KYC doesn’t expire on onboarding day: the relationship is monitored for as long as it lasts.
We hear them every week from fintechs, currency exchange houses, insurers and professional firms that serve international clients.
The client is a company, that company is owned by another company, and two layers later there’s no actual person in sight.
Every file is built by hand, with emails back and forth asking for documents that arrive incomplete or unreadable.
The information exists, but it’s scattered across emails, PDFs and spreadsheets. If the reasoning can’t be reconstructed, as far as the auditor is concerned it never happened.
Each jurisdiction has its own registry, its own language and its own level of public access. What works in one country doesn’t exist in the next.
A common surname matches a sanctions list and no one knows whether it’s the same person. The transaction stalls for lack of analysis, not because of real risk.
The business side wants speed, the regulator wants depth, and you’re the one who signs.
Each problem above is matched by a specific step in our procedure.
We trace the corporate structure up to the actual individuals and document each step with the registry it comes from. If the chain breaks, we say so and explain where and why.
Always the same structure and the same sections. Your team stops improvising each onboarding and the reviewer knows where to look.
Every data point carries its source and its search date. The file speaks for itself: who it is, what was checked, against what and when.
We work with corporate, court and sanctions registries in several jurisdictions, and we tell you upfront which ones are opaque.
When a name matches but the person is not the same, we record the identifiers that tell them apart. That is what unblocks the transaction.
You keep the decision and the signature. We do the documentation work behind it.
This is the order in which we carry it out and the order in which we deliver it.
The 31 CFR 1020.220 standard requires, at a minimum, name, date of birth, address and identification number. That is the floor, not the ceiling.
The FinCEN rule (31 CFR 1010.230) uses two tests: anyone who owns 25% or more of the equity, and the individual with significant responsibility for control. Both are documented.
The FATF defines a PEP as someone who holds or has held a prominent public function (Recommendation 12). Their close circle is reviewed as well.
Screening against OFAC’s SDN List and other restricted-party lists. OFAC civil liability is strict: it doesn’t depend on intent.
The activity expected from this relationship, so that anything that doesn’t fit can be recognized later. Without a profile, there’s nothing to trigger an alert.
It is the most common mistake: treating 25% as the only test. The FinCEN rule has two parallel prongs, and both are documented.
The ownership prong requires identifying every individual who owns 25% or more of the equity. The control prong also requires identifying, in every case, one individual with significant management responsibility: a CEO, a managing partner, a board member.
The practical consequence: a company with five partners at 20% each yields no beneficial owner under the ownership prong, and the file must still name the person who controls it.
Where we draw the line.
We carry out the documentary procedure, check the sources and deliver the findings with their supporting evidence. The final risk rating and the decision to accept or reject the client are yours: it is your acceptance policy and your signature.
We also do not give a legal opinion on your reporting obligations. That belongs to a licensed attorney or your designated compliance officer.
We work from published, cited regulations. You can check every reference.
FinCEN’s CDD Final Rule: it requires identifying and verifying the beneficial owners of clients that are legal entities, by ownership and by control.
The origin of the customer identification program. It is implemented in 31 CFR 1020.220, which sets the minimum required data.
It requires an AML program with internal policies, a designated compliance officer, ongoing training and independent testing.
The international customer due diligence standard, mirrored by regulators in Spain and Latin America.
Enhanced measures for politically exposed persons, their family members and close associates.
The risk-based approach: the depth of the review is scaled to the risk of each relationship.
We define which counterparty is reviewed, in which jurisdictions and to what depth. This determines whether the case calls for basic or enhanced due diligence.
We tell you exactly what to request from the client and what we obtain ourselves from public records, so you never ask for the same thing twice.
Corporate, court and sanctions registries. Every data point is logged with its source and its search date.
We trace the corporate chain to the individuals behind it under both prongs of the FinCEN rule: ownership and control.
Sanctions and PEPs. Matches are confirmed or cleared using identifiers, and clearances are documented too.
We deliver the report with the findings, the gaps that remained open and how often the relationship should be reviewed.
The file is delivered in English or Spanish, with technical terms in English where those are the terms your regulator will use. No improvised translations.
175 SW 7th Street, Suite 1905. A physical address you can verify in the financial district, not a mailbox.
The work is led by Zulma Eliana Bourelly, a Certified Anti-Money Laundering Specialist (CAMS), with a team trained in anti-money laundering (AML).
Not an email with conclusions: a file with sources, dates and gaps stated explicitly.
Everything is handled through documents and video calls, with no need to travel to the United States.
Information about your counterparties is handled with restricted access and is not shared with third parties.
KYC (Know Your Customer) is the set of procedures a company uses to identify a client, verify their identity against independent sources, understand the purpose of the business relationship and assess the money laundering risk they pose before accepting them.
KYC is the overall procedure for knowing your client. Due diligence is the depth at which that procedure is carried out in a specific case: basic when the risk is standard, enhanced when risk factors are present. KYC is the framework; due diligence is the level.
The formal obligation falls on financial institutions covered by FinCEN regulations, under 31 U.S.C. §5318(h) and 31 CFR 1010.230. In practice, many non-financial companies apply it because their banks, their insurers or their own counterparties require it.
It is the individual who ultimately owns or controls a client that is a legal entity. The FinCEN rule identifies that person through two tests: anyone who owns 25% or more of the equity, and the individual with significant responsibility for control of the entity.
Under the ownership prong, none of them reaches the 25% threshold. But the control prong still applies: the file must still identify an individual with significant management responsibility. A file left empty in that case is incomplete.
Under FATF Recommendation 12, it is someone who holds or has held a prominent public function. The status extends to immediate family members and close associates. Being a PEP is not a crime and does not rule out the relationship: it requires enhanced measures and documenting the source of funds.
The first step is to confirm that it’s the same person and not just a name match. If the match is real, the relationship cannot be treated like any other: OFAC civil liability is strict, meaning it does not depend on intent. We document the finding and the decision remains yours.
Yes, when the case calls for it. For PEPs, the international standard expressly covers the close circle, because that’s the usual channel for distancing funds from their real owner.
It is not a one-time task. Ongoing due diligence is part of the procedure: the relationship is reviewed periodically according to its risk level, and whenever something relevant changes, such as the ownership structure or the country of operation.
Yes. We work with registries in several jurisdictions. When a registry is opaque or not publicly accessible, we say so in the report instead of filling the gap with assumptions.
It is built for that: every statement carries its source and search date, and the gaps are stated. Your company is still the one answering to the regulator, and the file is the evidence of the procedure it applied.
No. We carry out the documentary procedure and deliver the findings with their supporting evidence. The risk rating and the acceptance decision belong to your company, under its own policy. We also do not give legal opinions: that belongs to a licensed attorney.
It depends on the number of jurisdictions involved and the depth of the corporate chain. After a first conversation, we give you a specific timeline in writing before we start.
Tell us what kind of counterparties you handle and who you answer to. We’ll tell you clearly what level of due diligence applies to you and what the file would contain.
or call us at +1 (305) 647-3000 · Monday through Friday
175 SW 7th St, Suite 1905 · Miami, Florida 33130
The standard level of verification for normal-risk relationships.
Sanctions, PEPs and KYE when risk factors are present.
Existence, good standing, ownership and litigation of a US company.
A public records search for marriages and divorces.
