SOLID KYC / AML Questionnaire

Please complete the questions that apply to your company. You can use the section links to move through the form.

Open the onboarding form →

01. — Client Info

1. Full Legal Name of the Client/Counterparty

2. Has the Client/Counterparty used any previous names or trading names within the last 3 years (if so, which ones)?

3. Government-Issued Unique Identification Number and Type

4. Country/State of Incorporation

5. Address of the Principal Place of Business

6. Is the correspondence (mailing address) different from the principal place of business address (if so, please state)?

7. Is the registered/legal address different from the principal place of business address (if so, please state)?
The registered/legal address is the address used by an entity for legal purposes, such as registration of the entity, service of legal process, and official correspondence. It may or may not be the same as the principal place of business address. The registered address is the same as the legal address.

8. Please provide a detailed description of the primary business activity in which the client/counterparty is engaged:

9. If the client/counterparty is regulated, listed, a government entity, or a subsidiary thereof (>50%), please provide the name of the relevant regulator/exchange/government and any further relevant information:

02. — Involvement with Sanctions & Sensitive Countries

10. To the best of your knowledge, does the counterparty have direct or indirect dealings, including but not limited to its operations, subsidiaries, partners, joint ventures, parent company, controllers, investment, and owners with or in any of the following countries/territories: Crimea region, Cuba, Democratic Republic of Congo, Iran, Libya, North Korea, Palestinian Territories (Gaza Strip and West Bank), Sudan (including Republic of South Sudan), Syria, Venezuela, Yemen, Zimbabwe?
Please provide details to describe and quantify the connection. Specifically, please provide an estimate of the percentage of current or forecast revenues from clients and operations in any of these countries.

11. Is the organization directly involved in physical transport of commodities and other goods?
If yes, does its business involve shipments to, through or from Iran, Cuba, Syria, North Korea and Crimea region)?
If yes, what percentage of its overall shipment volume is connected to these countries/region?

03. — Sensitive Industries

12. To the best of your knowledge, does the counterparty or any of its group companies (including but not limited to its parent and subsidiaries) and/or any of its controllers and owners, have connections to or involvement with any of the following business areas: Defense, arms or war materials (includes manufacture or distribution of goods, services or technology with a military application, dealers and intermediaries involved in such industries), Casinos, Betting or Gambling Industry, Extractive Industries (including energy minerals such as oil or gas, metallic both precious and base metals, and non-metallic minerals, or precious and semiprecious stones), Non-Bank – Banknote Dealers, Money Remittance/Money Services Business (Regulated/Unregulated), FX Retail Aggregators, Spread Betting, Virtual Currency Business (including Financial intermediaries offering virtual currencies related products), Pay Day Lending/Money Lending/Pawnbroker activities, Charities and/or Shipping?

13. Based on the CFTC's definition of a US Person, please indicate if the Client/Counterparty is a US Person (please refer to CFTC definition of US person below):

*Interpretation of the Term "U.S. Person"'

Proposed Interpretation Under the Proposed Guidance, the term "U.S. person" identifies those persons who, under the Commission's interpretation, could be expected to satisfy the jurisdictional nexus under section 2(i) of the CEA based on their swap activities either individually or in the aggregate.
As proposed, the Commission's interpretation of the term "U.S. person" would generally encompass:
(1) persons (or classes of persons) located within the United States; and
(2) persons that may be domiciled or operate outside the United States but whose swap activities nonetheless have a "direct and significant connection with activities in, or effect on, commerce of the United States" within the meaning of CEA section 2(i).
Specifically, as set forth in the Proposed Guidance, the Commission's interpretation of the term "U.S. person" would generally include, but not be limited to:
(i) any natural person who is a resident of the United States;
(ii) any corporation, partnership, limited liability company, business or other trust, association, joint-stock company, fund or any form of enterprise similar to any of the foregoing, in each case that is either (A) organized or incorporated under the laws of the United States or having its principal place of business in the United States (legal entity) or (B) in which the direct or indirect owners thereof are responsible for the liabilities of such entity and one or more of such owners is a U.S. person;
(iii) any individual account (discretionary or not) where the beneficial owner is a U.S. person;
(iv) any commodity pool, pooled account, or collective investment vehicle (whether or not it is organized or incorporated in the United States) of which a majority ownership is held, directly or indirectly, by a U.S. person(s);
(v) any commodity pool, pooled account, or collective investment vehicle the operator of which would be required to register as a commodity pool operator under the CEA;
(vi) a pension plan for the employees, officers or principals of a legal entity with its principal place of business inside the United States; and
(vii) an estate or trust, the income of which is subject to U.S. income tax regardless of source.
Under the proposed interpretation, a "U.S. person" would include a foreign branch of a U.S. person; on the other hand, a non-U.S. affiliate guaranteed by a U.S. person would not be within the Commission's interpretation of the term "U.S. person."

04. — Authorised Representatives, Shareholders & Relevant Beneficial Owners

14. Please provide list of Individuals with authority to act on behalf of the company. Please also provide evidence that these individuals have the requisite authority to represent the client. This can be achieved by sending one of the following documents (dated within the last 6 months) to legal@solid-fx.com:

- an authorised signatory list
- confirmation that the individual/s are on the Board of Directors
- completing and returning the Letter of Authority attached to the e-mail with this questionnaire; please ensure that this is headed with the principal place of business address of the entity and is signed by a director or equivalent officer

Please state for each Individual Given Name, Middle Name, Family Name, Date of Birth, Nationality, Position, Phone Number & E-Mail Address.

15. Please provide a list of the Relevant Beneficial Owners of the Client/Counterparty. This list should include both entities and individuals who hold 10% or more in aggregate (either directly or indirectly) of the voting and/or non-voting shares of the Client/Counterparty.
Please send a current ownership structure chart, detailing the names of all individuals/entities with holdings (directly and indirectly) in the entity to legal@solid-fx.com.
In addition to the names you are providing below, please confirm that no other individuals or organizations hold 10% or more in aggregate (either directly or indirectly) of the voting and/or non-voting shares of the Client/Counterparty.

Entities and Organizations

Please state for each Entity/Organization Full Legal Name, Country of Incorporation, Country of Principal Place of Business, Direct or Indirect Ownership, Total Ownership %.

Individuals

Please state for each Individual Given Name, Middle Name, Family Name, Country of Citizenship, Country of Residence, Date of Birth, Direct or Indirect Ownership, Total Ownership %.

For individuals with ownership of 10% or more, please send a copy of a government issued ID or passport and a description of their source of wealth to legal@solid-fx.com. By source of wealth we mean description of individual's financial standing or total net worth, i.e. those activities that have generated individual's fund and property. Generic source of wealth descriptions are not acceptable: 'savings', 'profits from investments', 'inheritance', 'business dealing, 'sale of business'.

16. Are any of the shareholders listed above acting as nominee shareholders?
If yes, please advise on whose behalf shares are held.

17. Can the client/counterparty issue share capital in bearer form*?
If yes, has the client/counterparty issued any share capital in bearer form?

*Bearer Shares are defined as issued unregistered share certificates or similar instrument that represents ownership of the company by whomever is in possession of the certificate.

05. — Day-to-day and Executive Control

18. Please provide the following information for all such individuals (e.g. the board of directors, CEO etc.) and/or entities who exert day to day/executive control over the Client/Counterparty.

Individuals

Please state for each Individual Given Name, Middle Name, Family Name, Date of Birth, Nationality, Country of Residence, Title/Position.

Entities and Organizations

Please state for each Entity/Organization Full Legal Name, Country of Incorporation, Country of Principal Place of Business.

19. Please provide the following information for all such individuals who exert ultimate decision making control over the Client/Counterparty. This section should include individuals who are not considered to be Directors, Managing Members, or day to day controllers. These individuals control would supersede that of the former. Please send a copy of government issued ID/passport for all such ultimate controllers to legal@solid-fx.com.

Individuals

Please state for each Individual Given Name, Middle Name, Family Name, Country of Citizinship, Country of Residence, Date of Birth, Title/Position.

20. Please confirm that all executive and day-today control lies with the directors and beneficial owners identified above. If there are other controllers besides these, please provide their name, nationality, date of birth and send a copy of a government issued ID/passport to legal@solid-fx.com.

21. Please provide information on the source of funds of the client/counterparty to be used in the relationship with Solid. This would be a brief statement regarding the name of the entity that is funding the account and whether or not it is the client itself (proprietary funds), an affiliate (e.g. underlying fund - client's funds) or an outside third party (third party's funds).

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