Otonomos provides a comprehensive range of nominee services to facilitate the incorporation and management of entities across various jurisdictions. This article outlines the services offered, their meanings, limitations, and Know Your Customer (KYC) processes.
We offer the following nominee positions:
Nominee (Corporate) Director
Nominee Shareholder
Nominee Supervisor
Nominee Manager
Nominee Member
Corporate Director
Local Director
These roles may vary in name depending on the jurisdiction and type of entity. For instance:
In a Limited Company (Ltd.), the term Nominee Director is used.
In a Limited Liability Company (LLC), the equivalent role is called Nominee Manager.
A nominee position involves appointing an individual or entity to act on behalf of another person, referred to as the beneficial owner.
Role of the Nominee:
Holds positions such as director, shareholder, or other formal titles.
Represents the beneficial owner's interests.
Acts as a custodian or placeholder without exercising rights or powers associated with the position.
Purpose:
Ensures the nominee's name appears on official company documents while the beneficial owner retains 100% control and responsibility.
Provides confidentiality for the beneficial owner on the official company documents
Analogy:
Nominees can be likened to a "VPN" for the company—visible on the surface but without having any control over the entity
Ultimate Beneficial Owner (UBO):
A nominee can never be considered the UBO of an entity.
The UBO individual must always be identified and provided by the client.
Liability:
Nominees are not liable for fines or penalties arising from the company’s failure to meet regulatory obligations.
When a nominee position is required to be onboarded with third parties, the following conditions apply:
Scope of KYC:
KYC is conducted only for the specific nominee position (e.g., Nominee Director or Nominee shareholder).
Nominees cannot be KYC’d as the UBO or legal representative of the client entity.
Additional Costs:
If a third party requests KYC for the UBO of the nominee entity, additional charges will apply.
If our assistance is required for onboarding with exchanges, market makers, or other third party service providers while we are acting as the Nominee, an additional onboarding fee of $1,200 per service provider will apply for further assistance.
Corporate Director Specifics:
Nominee directors provided by Otonomos are corporate entities (not individuals). KYC is performed solely in the capacity of a corporate director.
Document Sharing:
KYC documents related to nominees will be directly shared with the requesting third party on their platform and not via email to a particular person.