Execute · KYC and mandates

The questionnaire and the mandate, on one record.

An incoming KYC request is broken into requirements, and each is answered from the entity, ownership, officer and document records with the field it came from named beside it. The same record holds the bank accounts, the people authorised on them and the mandate that says what they may do.

Annual KYC refresh for Aldgate Holdings S.à r.l., reference APEX-KYC-2026-0431, in progress: the Overview, Requirements, Missing information, Documents and Activity tabs, then requirement 1, “Confirm the full legal name of the entity”, with its proposed response, the record field it was read from, and the Approve, Edit, Mark N/A, Request information, Attach evidence and Set subject actions.

Every proposed answer names the field it was read from · Approval recorded against a named person and time · Account identifiers masked to the last four digits

Intake

One request, broken into requirements.

A request arrives as an email, a questionnaire or a spreadsheet from a fund administrator, a bank or a counterparty’s compliance team. Paste the text as it was received, upload the questionnaire, or point at documents already on file. The wording is kept exactly as sent, and every requirement pins the question it came from, so an answer can always be read back against what was actually asked.

Each question is then classified against a fixed registry of 33 types, from legal name and registration number through to ultimate beneficial owners and source of wealth, so that it can be answered from records rather than from memory. A question with no match in the registry is marked as one for a person to answer, not guessed at.

Requirement 1, “Confirm the full legal name of the entity”, with the proposed response read from the record's legal-name field, the source named beneath it, and the six review actions along the bottom of the row.

The proposed answer

The field it came from, printed beside it.

Every proposed answer carries where it came from: the record and field it was read from, the method it was derived by and the date it was derived at, the document it cites, or the previously approved answer it reuses. Nothing is presented as a verified fact because the product produced it.

A person decides. Approve the answer, edit it, mark it not applicable, flag it as information still to be found and chase it as a task, attach the document that settles it, or point the requirement at a different subject. Approval is recorded against that person and cannot be written from a browser.

  • Approve
  • Edit
  • Mark N/A
  • Request information
  • Attach evidence
  • Set subject

What it answers from

The questions it can answer, and the states an answer can be in.

Question types

33 answered from records

  • Legal name
  • Registration number
  • Jurisdiction
  • Incorporation date
  • Registered office
  • Business purpose
  • Tax residence
  • Directors
  • Authorised signatories
  • Bank mandate signatories
  • Direct shareholders
  • Ownership percentages
  • Ultimate beneficial owners
  • Service providers
  • Auditor
  • Administrator
  • Tax adviser
  • Structure chart
  • FATCA classification
  • CRS classification
  • Source of funds
  • Source of wealth
  • Regulatory status
  • AML policy
  • Certificate of incorporation
  • Constitutional documents
  • Register of members
  • Structure chart document
  • Tax residency certificate
  • Bank letter
  • Passport
  • Proof of address
  • Bank account confirmation
and 25 more
  • Authorised signatories
  • Bank mandate signatories
  • Direct shareholders
  • Ownership percentages
  • Ultimate beneficial owners
  • Service providers
  • Auditor
  • Administrator
  • Tax adviser
  • Structure chart
  • FATCA classification
  • CRS classification
  • Source of funds
  • Source of wealth
  • Regulatory status
  • AML policy
  • Certificate of incorporation
  • Constitutional documents
  • Register of members
  • Structure chart document
  • Tax residency certificate
  • Bank letter
  • Passport
  • Proof of address
  • Bank account confirmation

The classified question types the answer resolvers cover. Anything outside the list is answered by a person.

Requirement statuses

7

  • Unanswered
  • Suggested
  • Needs confirmation
  • Missing information
  • Ready
  • Approved
  • Not applicable

Every state one requirement can hold. Approved is written by the server, so a proposal cannot become an approval on its own.

Where an answer is read from

  • The entity record's own fields
  • Ownership interests and shareholdings
  • Appointments and officers
  • Bank accounts and mandate holders
  • Service providers on the record
  • Documents already filed
  • A previously approved answer

The record types the answer resolvers read, and the provenance each answer shows.

Requirements 2 and 3 of the same request: “Provide the registration number”, answered B-249004 from the record's registration-number field, and “Provide the current registered address”, answered 15 boulevard Friedrich Wilhelm Raiffeisen, L-2411 Luxembourg from the registered-office field, each with the same six actions beneath it.

Review

Requirement by requirement, in the same shape.

Every row has the same shape: the question as it was asked, the proposed answer, the source, the status and the actions. What the records cannot answer is not left blank. It is recorded as missing data or as a missing document, with the reason it is missing, and counted on the request’s own Missing information tab, so the gaps are a list somebody can work through rather than a silence.

The response pack

Built from approved answers, and nothing else.

The pack cannot be generated until the request itself is approved, so a set of proposals can never leave the building as a response. What it contains is a spreadsheet schedule of the approved answers, a cover stating what it is and when it was produced, a beneficial-ownership section, and an index of the documents cited with links back to them.

An approved answer then joins the workspace’s answer library under the question it settles. The next questionnaire starts from what was agreed last time, proposed for confirmation rather than as settled fact, and an answer whose review date has passed or that a later version has replaced says so on the row instead of being reused quietly.

Bank mandates

Every account the group holds, and who may sign on it.

A bank account is held against the company that holds it, so it is never a row in a spreadsheet that has lost its entity. The Accounts tab lists them across the group with the bank, the currency and the account’s status. The Mandates tab turns the same records the other way round, one row per signatory, so the question a leaver raises is one screen rather than seven entity records.

The bank register on its Mandates tab: one row per signatory, with the company, the bank, the account and its masked reference, the authority that person holds, their approval limit, their status and the date the bank recognised them. Royal Bank of Scotland International and Banque Internationale à Luxembourg accounts sit together; some approvers carry no limit, others up to £150,000 or £250,000.
  • Accounts, Mandates and Controls
  • Identifiers masked to the last four digits
  • Every row opens the company that holds the account

What the mandate holds

Authority as a field, and the checks that read it.

On the account

  • Bank, currency, purpose and status
  • The signing rule, sole or joint, with its threshold
  • The board authority behind the mandate
  • The bank's mandate evidence and its expiry
  • The date the mandate is next reviewed

Fields on the account record. The review date can be tracked as a compliance obligation alongside the rest of the calendar.

On each signatory

4 authorities

  • View only
  • Originate
  • Approve
  • Administer

What one person may do on one account, with a per-transaction limit in the currency it is set in, the payment types and currencies it covers, and the dates they were added and removed.

Control checks

12

  • Nobody can approve a payment on this open account.
  • Only one approver — no two-person release is possible.
  • No originator named, so payments are input by someone the register does not know.
  • The only approver is also the only originator.
  • Still on the mandate after their appointment ended.
  • The bank's mandate evidence has expired.
  • The mandate review with the bank is overdue.
  • No board authority recorded for this account.
  • A live mandate at a bank with no named contact to write to.
  • Planned for a while with no sign of opening.
  • The bank has not confirmed a removal we asked for.
  • A closed account still carries live signing authority.

Run on every account the register shows, reported worst first with a severity.

The right-hand columns of the accounts table: currency, the signing rule, how many approvers the account has, the date the mandate is next reviewed and the findings against it. Any two jointly, any one signatory, and any one signatory up to £25,000 or €100,000 sit side by side; a review due 31 March 2026 is marked as overdue, and the findings column reads one finding, three findings, or a dash.

Controls

The signing rule, the approvers and the next review.

Because the authority is a field rather than a sentence in a policy document, it can be checked. The register reports where the mandate as recorded cannot work: an open account nobody can approve a payment on, a lone approver, an originator who is also that lone approver, a signatory still on the mandate after their appointment ended, expired bank evidence, a review that has gone past its date.

  • Sole, joint and group signing ladders
  • A per-person approval limit
  • Review dates tracked as obligations

One record

The same picture across every vehicle.

A group with thirty SPVs in four jurisdictions has thirty sets of accounts, signatories and repapering dates, and they usually live in a spreadsheet somebody rebuilds before each board meeting. Here they are fields on the entities themselves, so finance sees every account the group holds and governance sees who may act on it, filtered to one company, one bank or one person, without anybody rebuilding anything.

Alethia does not move money and has no view of a live payment. It records the mandate as agreed with the bank and reports what that mandate can and cannot authorise. A closed account is kept rather than deleted, because the question of who could sign on it three years ago still has to have an answer.

Bring a questionnaire you answered last quarter.

We load the entities it asked about and answer it in front of you, requirement by requirement, then show you the mandate behind the bank questions.