Business verification

1. What this is

This policy describes the know-your-business checks Lenz completes before Clive Alliance approves a customer, and the checks we repeat afterward. It is effective 19 October 2026 and is part of the Terms of Service and the AML and sanctions policy. An incomplete file is not approved. There is no exception for a company we already know.

2. The company

Nigeria

A Nigerian company is looked up on the Corporate Affairs Commission register and its tax identification number is checked with the Federal Inland Revenue Service. The legal name, registration number, incorporation date, and operating address must match those records or be explained with documents we accept. The check has to succeed before approval. If a registry is unavailable when the applicant submits, the application can wait, and approval still does not happen until the check has passed.

United States

A United States company provides its legal name, its employer identification number, the state of formation, the formation documents, and its operating address. The employer identification number is nine digits. Column N.A. verifies the entity when the account is opened. We do not approve the file on an incomplete set of formation documents.

Other companies

A company formed anywhere else provides its registry extract, its registration number, and its operating address. We review the documents by hand. We do not open an account for a company whose registry we cannot read and whose existence we cannot confirm.

Every company also states what it does, the countries it transacts with, where incoming funds will come from, and the monthly volume it expects. A company asking for a US dollar account also provides the last three months of operating-account statements and a short written explanation of the source of funds.

3. The people

We identify every natural person who is:

• the applicant;
• a director;
• a signatory; or
• a beneficial owner of 5 percent or more, directly or through another company, or a person who otherwise controls the company.

Five percent is the threshold we apply. It is stricter than the 25 percent threshold in the United States customer due diligence rule, and it is the threshold Nigeria uses for a person with significant control under the Companies and Allied Matters Act, 2020. Ownership must add to 100 percent, or the applicant must confirm that everyone not listed holds under 5 percent. A corporate owner at or above 5 percent is looked through to the natural persons behind it. We do not approve a file while a material owner is an unidentified company.

Nigerian nationals

A Nigerian director, signatory, or beneficial owner provides a Bank Verification Number and a National Identification Number. Both are checked against the national registries through our identity provider. A signatory also completes a liveness check and a face comparison against the portrait on the Bank Verification Number record. The numbers are stored encrypted and masked, as described in the Privacy Policy.

United States persons

A United States person provides a Social Security number or an ITIN and a date of birth. Column N.A. verifies that information when the business entity is created. A signatory also completes a liveness photograph, which compliance reviews.

Everyone else

Any other person provides a passport number, nationality, date of birth, and residential address. A signatory completes a liveness photograph. Compliance reviews the passport and the photograph before approval. We do not rely on an unreviewed passport.

Each person provides an email address and a phone number. The applicant’s email and phone are confirmed with a one-time code before the application can be submitted. A director who is not the applicant receives a link and enters their own identity information. They do not send those numbers through the applicant.

4. Authority to operate the account

The application states who can sign, and under what rule: any one signatory, or two together. The rule has to match the board resolution or other authority document in the file, and the reviewer records that it matches. Each signatory provides a specimen signature. For a naira account, each director and signatory also provides a next of kin, because the Nigerian partner requires it.

5. Screening and the decision

The company and every person in section 3 are screened as described in the AML and sanctions policy. Approval is blocked while a screening result is missing, has errored, or is an undecided potential match. A confirmed sanctions match cannot be approved.

Two people decide a file. One person reviews it and recommends approval. A different person approves it. A high-risk file, a politically exposed person, or confirmed adverse media requires the approver to be a compliance officer or a supervisor. The application as it stood at submission, and as it stood at approval, is stored and is not overwritten.

We may ask for more documents, a video meeting, or a site visit. We may refuse the application. We do not open the account at the partner until this decision is an approval.

6. After approval

Customers are reviewed on the cycle in the AML and sanctions policy. A customer whose review is due is asked to confirm that the company details are still current, and banking activity can be restricted if they do not. A new director or a new owner at or above 5 percent is verified before they are added. Screening is repeated while the relationship continues.

7. What we will not do

We will not approve on a screenshot in place of a registry check. We will not accept a beneficial-owner declaration that stops at a company. We will not tell an applicant the details of a sanctions or politically exposed person match. We will not use the model that drafts product copy to decide an application. Verification is a recorded check by a person, against a registry, a document, or a screening result.