Introduction
In the context where Defacto is granting loans (Prêts Participatifs) to its customers (SMEs in France and Europe), Defacto has set up Know You Business (KYB) procedures when onboarding new customers, to manage AML/CFT risks. These procedures were set in discussion with our lawyer firm Kramer Levin.
There are two cases of onboarding:
direct onboarding, where Defacto and its customer enters in a direct relationship
indirect onboarding, where customers are brought to Defacto through Partners. For example, Malt, the partner, is bringing freelancers (the customers) to Defacto.
Direct onboarding
The following information are shared between Defacto and the company:
Company information
Company identification number (SIREN in France)
VAT number
Company address
Recent company registry document (Kbis in France)
Bank account details (RIB in France)
Director information (director has to be mentioned on the Kbis)
First and last name
Email address
Phone number
Personal address
ID document (including date and place of birth)
Contract electronic signature
Information are stored and reviewed in a dedicated Notion note like this one: Onboarding Defacto.
Defacto can asks the company to update these pieces of information every 12 months.
Indirect onboarding
In case of indirect onboarding of a customer, introduced by a Partner
Defacto enters in a direct relationship with the Partner, and the Partner undergoes the previously described direct onboarding. Defacto and the partner signs a Partnership agreement contract.
Defacto only accepts customers that are “know” by the Partner, as mentioned in the Partnership agreement.
Defacto delegates to the Partner the collection of the previous documents.
The Partner sends the documents via API to Defacto, for storage and review.
Conclusion
We iterate on these procedures on a quarterly basis, to better adapt to the reality of our use cases and types of customers.
These guidelines may evolve after submitting a license application to the ACPR.