What is a KYC process and why do I have to do it?
KYC, short for “Know Your Customer,” requires financial and payment institutions to thoroughly identify and verify their customers before entering into a business relationship. The legal basis for this is the national regulation based on the European AML Directive, e.g. in Germany the Money Laundering Act (GwG) and the Tax Code (AO).
To do this, we need to collect information and documents about the company, the person involved, and the beneficial owners. This ensures that we know our customers and comply with legal requirements.
Legal entities, registered merchants, associations, etc., who are customers of Moss GmbH and would also like to use our financial products (credit card, Pay with Moss) must go through this KYC process as part of the onboarding process.
Germany / EU / EEA
Germany / EU / EEA
The legal basis for this in Germany is, in particular, the Money Laundering Act (Geldwäschegesetz, GwG) and the Tax Code (Abgabenordnung, AO). As Moss GmbH offers its services from Germany to the Netherlands, Austria, and other member states, German law applies.
United Kingdom
United Kingdom
The legal basis for this in the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), and guidance provided by the Financial Conduct Authority (FCA) and the Joint Money Laundering Steering Group (JMLSG).
What documents are required for the KYC process?
The exact documents required depend on various factors, such as the legal form of your company or the industry in which you operate. We try to obtain as much information as possible from publicly available sources (e.g., the commercial register) ourselves in order to make the process easier for you.
However, we may require additional documents, such as the following:
Identification process of the person(s) involved by means of ID card/passport; additional proof of address if necessary
Power of attorney if the person involved is not registered as a legal representative in the register
Current, signed list of shareholders showing the beneficial owner(s)
Description of your business model; if applicable, supporting documents such as bank statements, invoices, or complete annual financial statements
If applicable, a copy of the ID of the beneficial owner(s)
How does the identity verification process work?
All legal representatives, i.e., those who enter into the contractual relationship with Moss on behalf of the legal entity, must confirm their identity by means of a valid ID document.
Germany / EAA (except the Netherlands)
Germany / EAA (except the Netherlands)
We use the “VideoIdent” procedure provided by our partner IDnow for this purpose.
Only a valid identity card, passport, or residence permit (e.g., EU Blue Card) are accepted for the identity verification. We cannot accept other documents such as registration certificates, driver's licenses, or company ID cards.
Netherlands / United Kingdom
Netherlands / United Kingdom
We use the so called “auto ident” procedure provided by our partner Onfido for this purpose.
We can accept a valid identity card, passport, residence permit or driver's license for the identity check. We cannot accept other documents such as registration certificates or company ID cards.
What is the legal ground for the KYC?
Germany / EU / EEA
Germany / EU / EEA
As a licensed e-money institution, Moss GmbH is a “obliged entity” pursuant to Section 2 of the German Money Laundering Act (Geldwäschegesetz, GwG), similar to a bank or tax advisor.
As such, it must comply with the general due diligence obligations pursuant to Section 10 GwG, including “the identification of the contractual partner and, where applicable, the persons acting on its behalf [...]”. The permissible procedures and requirements are described in the following paragraphs.
In addition, the provisions of Section 154 of the German Fiscal Code (AO) and other regulatory requirements, such as those of the BaFin, also apply.
United Kingdom
United Kingdom
In the UK, financial institutions are required by law to verify their customers’ identity before entering into a business relationship. This is part of the anti-money laundering obligations under the UK Money Laundering Regulations.
We are cooperating with the licensed E-Money Institutions Airwallex (UK) Limited and Transact Payments Limited to provide you with financial servies.
Their requirements are similar to those of banks and ensure we comply with UK financial regulations.
How long does it take to open an account?
We endeavour to complete the process within two working days of receiving all necessary information and documents.
Please understand that delays may occur in individual cases, for example if further documents are required.
How often do I have to perform the KYC process?
As a rule, only once per company. If affiliated companies become customers, we try to use existing information, such as information on persons or beneficial owners.
What kind of IBAN will I receive?
Germany / EU / EEA
Germany / EU / EEA
As a German e-money institution, Moss GmbH works with Deutsche Bank AG and therefore offers you a German IBAN (DE...).
United Kingdom
United Kingdom
In cooperation with our partner Airwallex (UK) Limited, customers receive an “account number” and a “sort code.” IBANs are not issued in the UK.
What legal forms are accepted?
We generally accept all legal forms customary in Germany, Austria, the Netherlands, and the rest of the EEA that are entered in a public register.
These include, but are not limited to
Germany and Austria
Germany and Austria
GmbH and UG, including non-profit organizations
AG and SE
GmbH & Co. KG
e. V.
e. K.
Partnerships
KdÖR
Stiftungen
Netherlands, France, and the rest of the EEA
Netherlands, France, and the rest of the EEA
B.V.
N.V.
S.E.
SARL
SRL
SAS
SCA
United Kingdom
United Kingdom
LTD
PLC
LLP
GLV
Charitable incorporated organisations, if they are registered in the Register of Charities
Unfortunately, unregistered merchants, such as self-employed persons or freelancers, are currently unable to use our financial services. However, they can use our software services.
Does Moss have its own licence?
Germany / EU / EEA
Germany / EU / EEA
Yes, Moss GmbH is an e-money institution registered in Germany and approved and supervised by the Federal Financial Supervisory Authority (BaFin).
You can find our registration here.
United Kingdom
United Kingdom
In the UK, Moss works with licensed partners to provide financial services:
Airwallex (UK) Limited provides you the wallet and payment services and is authorised and regulated by the Financial Conduct Authority (FCA).
Transact Payments Limited issues Moss Cards and is authorised and regulated by the Gibraltar Financial Services Commission (GFSC).
In addition, GetMoss UK Ltd. offers credit facilities to eligible customers in the UK and is an Annex 1 firm under UK AML regulations.
Is my data secure? Who has access to it?
Yes, Moss works according to the highest industry standards, is ISO/IEC 27001:2022 certified, and GDPR compliant. We follow the “Privacy by Design” principle and use data hosting within the EU.
More information at: getmoss.com/en-us/security
Is Moss a bank?
No, Moss is not a bank, but depending on the country, we either have our own license or work with licensed partners (see below).
Germany / EU / EEA
Germany / EU / EEA
We are a German e-money institution. As such, we are licensed and supervised by the Federal Financial Supervisory Authority (BaFin). As such, we have the right to provide all financial services necessary for our products, such as issuing payment instruments, payment card business with and without credit, or financial transfer business.
United Kingdom
United Kingdom
In the UK, we work with licensed partners to provide financial services:
Airwallex (UK) Limited for wallet payment services (except cards),
Transact Payments Limited for Moss Cards,
GetMoss UK Ltd. for credit facilities.
All these services are fully regulated under UK and Gibraltar financial regulations.
What is a legal representative?
The legal representative is the person represents the company and enters into the contractual relationship with Moss. As a rule, this is a managing director, board member, or authorized signatory as listed in the commercial register; if applicable, several persons may act jointly.
If a person not listed in the commercial register represents the company, we require a corresponding power of attorney.
What is a beneficial owner?
A beneficial owner is a natural person who ultimately owns or controls a company.
Germany / EU / EEA
Germany / EU / EEA
Beneficial owners within the meaning of the German regulation (GwG) are natural persons who own or control a company.
According to Section 3 GwG, these include, in particular, persons who directly or indirectly
control more than 25% of the capital shares or voting rights, or
exercise control in a comparable manner (e.g., through veto rights).
In individual cases, the determination may be somewhat more complicated. Please understand, that we have to apply German regulation that might lead so slighlty different results than other local European rules. We will contact you with any questions if necessary.
United Kingdom
United Kingdom
Under UK anti-money laundering regulations, this typically includes anyone who:
directly or indirectly holds 25% or more of the shares or voting rights, or
otherwise exercises significant control over the company (e.g., through veto rights).
In some cases, identifying the beneficial owner can be more complex. If we have any questions, we will of course contact you during the process.
What can I use to identify myself during the identification process
Germany / EAA (except the Netherlands)
Germany / EAA (except the Netherlands)
We use the “VideoIdent” procedure provided by our partner IDnow for this purpose.
Only a valid identity card, passport, or residence permit (e.g., EU Blue Card) are accepted for the identity verification. We cannot accept other documents such as registration certificates, driver's licenses, or company ID cards.
Netherlands / United Kingdom
Netherlands / United Kingdom
We use the so called “auto ident” procedure provided by our partner Onfido for this purpose.
We can accept a valid identity card, passport, residence permit or driver's license for the identity check. We cannot accept other documents such as registration certificates or company ID cards.
Can I become a Moss customer as a company in the process of being established?
Unfortunately, we are currently unable to offer financial services to companies that are still in the process of being established. However, you can still use our software services.
As soon as the company is entered in the register, we will be happy to carry out the onboarding process.
Can I become a Moss customer as a self-employed person/freelancer?
Unfortunately, we are currently unable to offer our financial services to customers that are not an officially registered company or merchant in a commercial register. However, you can still use our software services.