AML and UBO Checks for the VIES Guarantee: Why They Are Required and Which Documents to Prepare

For many non-EU companies, the most unexpected part of the VIES guarantee file is not the guarantee itself — it is the identity checks. Before the policy can be issued, the identity of the company’s beneficial owners must be verified under Italian anti-money-laundering rules. This article explains why these checks exist, who counts as a beneficial owner, and which documents to prepare so they do not become the bottleneck of your application.

Why an insurance intermediary must verify your identity

Italian anti-money-laundering law (Legislative Decree 231/2007) requires insurance intermediaries — like banks, notaries and other regulated operators — to perform customer due diligence before establishing a business relationship. In practice this means identifying the company, verifying the identity of the people acting on its behalf, and identifying its ultimate beneficial owners. These checks are a legal duty of the intermediary, applied to every client: they are not a sign of distrust towards foreign companies, and they cannot be waived.

Who counts as an ultimate beneficial owner (UBO)

The beneficial owner is the natural person — or persons — who ultimately owns or controls the company. Under the criteria of Legislative Decree 231/2007, direct or indirect ownership above 25% of the capital is the main indicator; where no person meets that threshold, control exercised through other means is considered, and residually the persons holding legal representation or direction powers. For companies held through multi-tier or cross-border structures, the ownership chain must be reconstructed up to the natural persons at the top — which is precisely where good preparation saves the most time.

Which documents are typically requested

• An up-to-date extract from the company registry of the country of incorporation (or equivalent certificate).
• Articles of association or equivalent constitutional documents.
• Identity documents of the legal representative and of each beneficial owner.
• For multi-tier structures: an ownership chart showing the chain of control up to the natural persons.

The exact list depends on the company’s structure and country of origin; documents issued in other languages may need to be accompanied by translations. Your point of contact will confirm the specific set for your file.

How the checks work remotely

None of this requires travelling to Italy: identification and signature can be completed remotely through the procedures described in how to sign an insurance guarantee from abroad without an Italian tax code. Where the file is handled through the fiscal representative, the rules on authorisation are covered in what non-EU companies must know about the power of attorney, and the rules on who may pay the premium in who can pay the premium for a policy issued in Italy.

Prepare early

AML and UBO checks are the part of the file most dependent on the client: the earlier the documents are ready, the smoother the rest of the procedure runs. For the complete picture of the VIES guarantee process, see VIES registration for non-EU companies.

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