KYC-005 — Corporate onboarding: Hold (UBO opacity via nominee-held HoldCo in high-risk jurisdiction) | Notion

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Fictional case for portfolio training only. No real person, company, or jurisdiction. Not a real STR. Not legal advice. Not investment advice.

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Snapshot

Field	Detail
Case ID	KYC-005
Case type	Corporate onboarding
Platform	Simulated SFC-licensed VATP
Applicant	Company D (mid-risk jurisdiction J)
Product	Corporate account: spot trading + fiat on/off-ramp
Expected activity	~USD 8m / month
Risk rating	High → EDD
Key issue	UBO opacity via nominee-held HoldCo in high-risk jurisdiction H
Decision	Hold (not Pass, not Reject yet)
Deadline	30 days → Reject + MLRO STR assessment if not remediated

Facts

Applicant and request

Company D, incorporated in mid-risk jurisdiction J, applies for a corporate account on a simulated SFC-licensed VATP.
Requested services: spot trading and fiat. Expected volume ~USD 8m per month.

Ownership and control

Company D is 100% owned by HoldCo F, incorporated in high-risk jurisdiction H.
HoldCo F's registered shareholder is Nominee G.
Client states UBO E owns 60%. The remaining 40% is described only as "financial investors" and is unnamed.
Company D's sole director is a corporate director.
The account authorised person is an employee of Nominee G.

Red flags

Multi-layer structure with a holding layer in high-risk jurisdiction H.
Trust deed provided as a scan only: unsigned and undated.
40% of ownership unidentified.
E's address proof does not match the address on E's ID.
Vague source of wealth: "early crypto gains", with no wallet addresses or records.
First deposit received from a third-party exchange, not from an account in Company D's name.