Bastion Capital London Limited

Customer Due Diligence

Before a customer can use the account, prove they are who they say they are using reliable, independent evidence, not just what they typed into the form.

Starting threshold:

100% of mandatory identity attributes matched to >=1 independent source before activation; for individuals require 2 of 3 attributes from electronic verification OR 1 authenticated photo-ID document plus a passing liveness check; document image quality / face-match confidence >= 90%.

First-line owner:

Onboarding / KYC Operations team

Customer Due Diligence

For any company or trust customer, find out who really owns or controls it (the actual humans), and prove it, before letting them transact.

Starting threshold:

>25% direct or indirect ownership/voting rights defines a beneficial owner; verify identity of every such person; require the full chain to be resolved to natural persons within 3 ownership layers before activation, or document why a deeper/opaque chain is acceptable.

First-line owner:

KYC Operations / Corporate Onboarding team

Customer Due Diligence

At sign-up, ask and record what normal looks like for this customer (how much, how often, to where) so monitoring can later spot when they behave nothing like that.

Starting threshold:

Profile mandatory for all customers; for higher-risk customers require itemised expected monthly turnover, expected corridors and expected counterparties. Flag for review where declared turnover exceeds 3x the income/turnover implied by occupation or filed accounts, or where declared geographies include high-risk jurisdictions not explained by the stated business.

First-line owner:

Onboarding / KYC Operations team

Customer Due Diligence

Score each new and existing customer for money-laundering risk from clear factors (who they are, what they do, where they are) so the firm spends most effort on the riskiest ones.

Starting threshold:

3-band model: high if any override (sanctions nexus, PEP, high-risk-jurisdiction nexus per reg.33) OR weighted score >=70/100; medium 40-69; low <40. High = EDD + annual review; medium = standard CDD + biennial review; low = simplified where permitted + triennial review.

First-line owner:

KYC Operations / Onboarding team (with model owned by Compliance)

Customer Due Diligence

For a specific large or unusual deposit, establish and evidence where that exact money came from before it is used.

Starting threshold:

Verify source of funds for any single inflow >= GBP 10,000 (or local equivalent) or aggregated inflows >= GBP 10,000 in 30 days; lower to GBP 0 (verify all) for high-risk and PEP relationships; always verify where the payer differs from the customer or the funds originate in a high-risk third country (reg.33).

First-line owner:

Relationship Management / Onboarding with KYC Operations

Customer Due Diligence

For high-risk and PEP customers, understand and prove how they built their overall wealth (not just one deposit), and make sure that story is plausible and independently corroborated.

Starting threshold:

Mandatory documented and corroborated source of wealth for all high-risk and PEP relationships before onboarding; flag for escalation where corroborated wealth covers less than 75% of estimated net worth, or where wealth exceeds 10x the customer's known/declared legitimate income or official remuneration with no documented explanation.

First-line owner:

Relationship Management (private banking / wealth) with KYC support