Security and Compliance at Holvi
Customer Identification and Due Diligence
Holvi is a licenced Payment Service Provider operating under the supervision of the Finnish Financial Supervisory Authority (FIN-FSA) as well as the German Financial Supervisory Authority BaFin and Federal Ministry of Finance (“BMF”) (http://www.bundesfinanzministerium.de) (applicable to customers with DE accounts). Holvi is required to comply with customer identification and due diligence standards, which means that we must identify and know our customers. In addition to personal details of the customer, we must have sufficient information on the customer’s activities, financial position, banking practices and purpose for which the services are used.
We also want to know our customers to be able to give them good advice and offer services best suited to their needs. However, some of the questions or required information are based on other reasons – as a Payment Institution, we are obligated and committed to preventing financial crime like money laundering, tax evasion and terrorism financing, as well as illegal activities such as fraud attempts, ID theft, human trafficking or drug dealing. Preventing money laundering is not only in Holvi’s best interest – when a customer provides his or her information, they are supporting our work against crime as well as our ability to provide quality services to society as a whole.
Holvi is subject to applicable Finnish, EU and international anti-money laundering (AML) laws and regulations. Holvi seeks to make sure that any updates to relevant legislation and technical standards are followed and that our processes are also updated accordingly. Holvi has established adequate internal controls, procedures and guidelines, has appointed a reporting officer, and performs continuous staff training programs in order to comply with customer due diligence standards and AML requirements.
These requirements are the same for all entities supervised by one of the authorities mentioned above. However, some entities might accomplish this in different ways and at different times. Please visit FIN-FSA Customer Due Diligence or see the German Money Laundering Act (GwG) for more information.
KYC - Know Your Customer
Holvi is a fully digital service. We do not require our customers to pay a physical visit to our office in order to get started with a Holvi business account. Instead, we ask our customers to provide, through various channels (e.g. per E-Mail or phone), the personal and business identification documentation necessary for identification and verification. Besides personal details of the customer, we must also gather sufficient information on the customer’s business activities, financial position, banking practices and purposes for which the services are being used.
Depending on the customer's residence, the questions or required documentation may vary. Any information or documentation that we receive is treated in compliance with the Finnish guidelines on banking secrecy.
Politically Exposed Persons
With the current Finnish legislation, we are also required to know whether the customer is a Politically Exposed Person (PEP). A Politically Exposed Person is an individual who is or has been entrusted in the past twelve months with a prominent public function. Family members and close business associates of PEPs are also considered PEPs themselves. Examples of Politically exposed positions are:
(a) Head of State, Head of Government, Minister, Deputy or Assistant Minister;
(b) as a Member of Parliament or of similar legislative bodies;
(c) a member of the governing bodies of political parties;
(d) a member of the Supreme Courts, the Constitutional Court or any other similar judicial body, whose decisions may not, except in exceptional cases, be appealed;
(e) a member of the Supreme Audit Institution of the Court of Auditors and the State Audit Office;
(f) a member of the Governing Board of the Central Bank;
(g) as ambassador or as trustee;
(h) at least as a military officer in the Armed Forces;
(i) a member of the administrative, management and supervisory body of a wholly-owned State enterprise; or
j) Director, deputy director and board member of international organizations;
k) Members of the European Commission (EC)
i) State secretaries
In addition to business documents that are being verified during your account application, we are obligated to obtain, among others, information about the business sector, nature and extent of the business operations, turnover, structure and ownership of the company. To comply with these information requirements, we may request additional information like financial statements, articles of association and other documents deemed necessary; depending on the country where the company is registered, the required documents may vary on a case-by-case basis.
Business representatives must also be identified and their identities verified. We are also required to identify the owners and/or the actual beneficiaries, so-called “beneficial owners” of the company, and, if necessary, verify their identities.
Information on funds involved in transactions
Customer due diligence requires that we know on whose orders transactions are made and with whose funds. In certain cases, we may inquire about account transactions volumes, including the origin and purpose of the transaction. In some cases, we may also need to ask for documentation evidencing business operations, registration or any other proof (e.g. sale contract) in addition to a written statement relating to such transaction that may help us to verify the source of funds and the purpose for which the funds are used.
If we are not able to collect the required information in order to support the execution of a transaction, we might not be permitted to provide you with a full range of our services or may even be forced to reject the transaction.
Records must be retained
As a supervised entity, we have specific recordkeeping requirements. Records and documentation related to customer identification and due diligence information need to be stored for a minimum period of five years after the termination of a customer relationship.
We encourage our customers to get in touch with us if they suspect or have knowledge about money laundering activities, have been a victim of fraud or identity-theft, report misuse, ask questions or give feedback on data security issues.
Please note that you cannot send any questions to the address above; this channel is solely meant for reporting suspicions of fraud. You will not get a reply to your e-mail, but your information can help to prevent money laundering and terrorist financing, as well as to track and stop other illegal activities.