KYC Checklist for Corporate Clients

When a business takes on a company as a client, it has to know who is really behind it. The KYC requirements for a Mauritius company are not a single form: they are a set of documents and checks that grows with the risk the client presents. This page lists what to collect, in what order, and what changes when the file moves from standard to enhanced checks.

It is general information, not advice. What your own file must contain depends on your activity, your risk assessment and your supervisor's expectations, so confirm the final list with an adviser.

Who has to carry out these checks

The Financial Intelligence and Anti-Money Laundering Act (FIAMLA) places obligations on "reporting persons". A Company Service Provider is among the professions listed in the schedule to the Act, with the Registrar of Companies as its regulatory body. An FSC-licensed corporate service provider (Management Licence) therefore identifies its corporate clients under these rules, and so do other regulated businesses that take on companies as customers.

A company that is not itself a reporting person still has its own identification duty: it must know its beneficial owner at all times. That is a separate exercise, covered in the beneficial ownership register guide.

For the wider framework, start with AML/CFT compliance for Mauritian companies.

Customer due diligence: when it applies

Customer due diligence (CDD) is triggered when an account or business relationship is opened. For an occasional client, it applies from a transaction of Rs 500 000 or the foreign-currency equivalent (or the prescribed amount), whether single or linked, and to any domestic or cross-border wire transfer (section 17C of the FIAMLA).

In practice, a corporate client taken on for continuing services is a business relationship from day one, so the full file is built before work starts.

The three layers of a corporate KYC file

A useful way to organise the file is in three layers. Each answers a different question.

Layer 1: the entity

You need proof that the company exists, is in good standing and does what it says.

• Certificate of incorporation or registration, with the registration number.
• Constitution (or equivalent constitutive document).
• Registered office address and, where different, the address of actual business.
• Description of the business activity and where it is carried out.
• Evidence of authority: a board resolution or mandate naming who may instruct you.

For a company limited by guarantee, the file should also hold the document signed by each member recording consent and the amount the member undertakes to contribute on winding up. A one person company should show who is named to act as secretary and to convene a meeting of heirs on the sole director's death.

Layer 2: the people who run it

• Full name, residential address and identity document of each director and of the secretary.
• Specimen signatures or confirmation of who signs.
• For a company that needs a resident director, a note of who holds that role. See resident director requirements.

Layer 3: the owners

This is the layer supervisors look at first. The company's own beneficial ownership record is a good starting point, because the Companies Act requires it to hold, in a separate register, each beneficial owner's:

• full name and residential address;
• national identity number or passport number;
• nationality;
• holding structure identifying the ultimate beneficial owner.

Who qualifies as a beneficial owner is explained in who counts as a beneficial owner; this page only deals with the paperwork.

Since the Finance Act 2025, identification of the beneficial owner must include a written declaration from the beneficial owner personally. Companies incorporated before that change had until 30 June 2026 to comply, and the beneficial owner must tell the company of any change in status. Ask for that declaration, dated and signed, and keep it in the file.

The Corporate and Business Registration Department (CBRD) publishes on its Guidelines page a document titled "BO Guidance – Identification of Beneficial Owners under the Companies Act 2001", dated 5 October 2026. Its detail should be read directly before you finalise your own procedure.

What to collect, by risk level

The depth of the file follows the risk. Section 17 of the FIAMLA requires each reporting person to identify, assess and understand its money laundering, terrorist financing and proliferation financing risks (clients, geographic areas, products, services, transactions and delivery channels) and to set its mitigation measures accordingly. How to score a client is the subject of business risk assessment for AML purposes; the table below assumes the score is already known.

Source of funds and source of wealth are treated in source of funds and source of wealth.

Enhanced due diligence in Mauritius

Enhanced due diligence is not a separate form but a heavier version of the same exercise. It is typically triggered by:

• a complex or opaque ownership structure, or a nominee in the chain;
• a politically exposed person among the owners or directors (see politically exposed persons);
• a link to a high-risk jurisdiction;
• unusual activity or an unexplained business rationale.

On the geographic point, section 17H of the FIAMLA allows the Minister, on the National Committee's recommendation, to designate as high-risk a country that the Financial Action Task Force has identified as having strategic deficiencies. Enhanced measures then apply to transactions involving that country. Check the current designation list each time rather than relying on an older file note.

Enhanced checks also mean a decision-maker above the account manager approves the relationship, and that the reasons are written down.

Decision path: which level of checks?

If the relationship cannot be completed, the question of a report is handled under suspicious transaction reports and, for the filing channel, registering with the FIU and using goAML.

The KYC checklist

Use this as a working list for each corporate client. Tick items only when the document is in the file and has been checked, not when it has merely been requested.

• Certificate of incorporation or registration, with registration number
• Constitution or equivalent constitutive document
• Registered office and business address recorded
• Nature of business and place of activity described
• Board resolution or mandate naming authorised signatories
• Directors and secretary: identity documents and residential addresses
• Beneficial owner(s): full name, address, NIC or passport number, nationality
• Written declaration signed by each beneficial owner
• Structure chart to the ultimate natural person
• Nominee arrangements identified, if any
• Source of funds recorded; source of wealth where risk requires it
• Politically exposed person and sanctions screening done and dated (see sanctions screening)
• Risk rating recorded with the reason
• Enhanced measures and senior approval, where the rating requires them
• Review date set

Keeping and updating the file

CDD records, meaning the identity documents of clients and beneficial owners, must be kept for at least 7 years after the business relationship ends. Transaction records are kept for 7 years after the transaction, and copies of suspicious transaction reports for at least 7 years after filing (section 17F of the FIAMLA). The wider record rules are in company records: what to keep and for how long.

On the company side, the beneficial ownership register and any information required about owners must be accurate, up to date and made available without delay to the competent authorities on request. The Registrar of Companies keeps a Beneficial Ownership Register that is accessible to competent authorities and prescribed public authorities; the Companies Act does not describe it as a public register. A company that fails to file beneficial ownership information can be struck off under section 309(1) of the Companies Act.

A file is only as good as its last review. Re-check it when ownership changes, when a director is replaced, when the activity shifts, or when screening produces a new alert. The person responsible for oversight is usually the money laundering reporting officer.

Common gaps in corporate files

• A structure chart that stops at a holding company instead of reaching a natural person.
• A beneficial owner declaration that is unsigned, undated or older than the last ownership change.
• Identity documents copied but never compared against the owner's stated address.
• A risk rating with no reason recorded.
• Screening done once at onboarding and never repeated.