Know Your Customer (KYC)
and updating your information
As a bank, we are committed to maintaining the security and accuracy of our clients’ data. This commitment stems not only from regulatory requirements but also from our goal to ensure reliable and secure banking services.
For this reason, we regularly conduct the Know Your Customer (KYC) process and update client data. This process is carried out periodically and applies to clients of all banks.
Customer due diligence or KYC
Customer due diligence, also known as KYC (Know Your Customer), is the process of collecting and verifying client information to prevent misuse of the banking system and to ensure compliance with regulatory requirements.
It includes verifying the client’s identity, understanding the purpose of the business relationship, confirming the source of funds, and ensuring compliance with international sanctions.
The fastest and simplest way to complete the Know Your Customer process is via NetBanking or mBanking. The process can only be completed by the legal representative who is authorised to represent the business entity independently and individually.
Questions and answers
For business clients, the KYC process covers:
- identification of the legal entity and authorised representatives,
- verification of the ownership structure and beneficial owners,
- assessment of money laundering and terrorist financing risk,
- verification of tax status and politically exposed person (PEP) status.
If a higher level of risk is identified, additional documentation may be required. Client cooperation is a legal obligation, and missing or suspicious information may result in the rejection of a transaction or the termination of the business relationship.
- Questionnaire for clients business entities
- Politically exposed person statement (if PEP YES - additional proof of assets or funds will be required)
- Proof of identity for authorised representatives (copy of identity card or passport)
Depending on the type of your business, additional documentation may be required.
Companies (joint-stock companies, limited liability companies, simple limited liability companies), institutions and cooperatives
- Decision of the Commercial Court on establishment or an extract from the court register, not older than three months
- Extract from the Register of Beneficial Owners, not older than one month
- Founding act, Articles of Association - Statute
If a legal entity is part of the ownership structure, you also need to provide:
- Extract from the relevant register for all legal entities in the ownership structure, in Croatian or English, not older than three months
Attorneys
- Decision of the Croatian Bar Association confirming entry into the register of attorneys
- Notice from the Croatian Bar Association on the assignment of the registration number
Notaries public
- Decision of the Ministry of Justice appointing the client as a notary public with the registered office indicated
- Notice from the Croatian Chamber of Notaries on the assignment of the registration number
Local councils, cities and municipalities
- Decision appointing members of the Local Council issued by the municipal executive authority
- Copy of the appointment decision published in the official gazette
- Copy of the decision on the election of the mayor issued by the city election commission
- Copy of the decision on the election of the municipal head issued by the municipal election commission
Craft businesses (sole traders)
- Decision issued by the competent economic authority or an extract from the Craft Register, not older than three months
Family farms (OPG)
- Decision of the State Administration Office confirming the registration of the client as the holder of a family farm
- Certificate of assignment of the farmer’s registration number
- Extract from the Register of Family Farms
Athletes and independent professions
- Decision issued by the Office for education, culture and sport confirming the client’s entry in the register
- Registration decision issued by the Croatian Association of Independent Artists confirming the status of an independent artist
Tourist boards
- Extract from the official website of the public authority showing basic information about the tourist board
- Decision appointing the director
Associations
- Extract from the relevant register of associations, not older than three months
- Extract from the Register of Beneficial Owners, not older than one month
Religious institutions
- Extract from the relevant register of religious communities
- You can update your data quickly and easily via NetBanking or mBanking – simply complete the forms and upload the required documentation. Data can be updated only by persons authorised to represent the business entity independently and individually.
- If you prefer to update your data by e-mail, send the documentation to kyc.support@erstebank.hr from the contact email address you provided when establishing our business relationship.
An authorised representative of the business entity can also submit the documentation at any of our branches.
If the required data is not submitted within 90 days of receiving the notification, we will temporarily restrict the use of existing products and services, as well as the contracting of new ones, until the required documentation is provided.
In addition, 20 days before the deadline, it will no longer be possible to contract new loan products or letter-of-credit/guarantee products outside already approved limits.
You can submit the required data quickly and easily via NetBanking or mBanking. The process has been adapted to your business rhythm, allowing you to update your data gradually and continue the process at any time from where you left off.
If we do not receive the required data within 90 days after the temporary restriction, the use of products and services will be permanently disabled and the process of terminating the business relationship may be initiated.
For this reason, the KYC process in NetBanking and mBanking has been designed so that you can complete it easily, on time, and without the need to visit a branch.
- when establishing a business relationship,
- periodically during the business relationship.
We regularly update client data, and the frequency of periodic checks depends on the risk profile of the business relationship.
A politically exposed person is any natural person who currently holds, or has held within the past 12 months, a prominent public function in an EU Member State or a third country. This definition also includes their immediate family members and individuals known to be close associates of such persons.
1. What is the ownership structure?
The ownership structure shows all persons or entities that hold shares, voting rights, or any other form of control in your business entity.
We are required to determine the entire ownership structure of the client, regardless of the size of individual holdings, in order to identify the natural person who is the ultimate beneficial owner and who has effective influence over the company’s operations.
2. Who is the ultimate beneficial owner?
The ultimate beneficial owner is the person who ultimately controls the business entity and has effective influence over its operations. The beneficial owner may be:
- Direct owner – a person holding a significant ownership interest, shares or voting rights (usually more than 25%).
- Indirect owner – a person holding significant ownership or control through one or more related persons, business entities or trusts.
- Control by other means – a person who exercises control or significant influence in another way, even without formally holding an ownership interest.
For organisations such as foundations, associations, political parties or trusts, the beneficial owner is the person who represents them or holds a controlling position in managing their assets and operations.
3. What if no one holds more than 25%?
We are still required to determine the entire ownership structure of the client. Based on this information, we calculate whether anyone meets the 25% threshold for direct or indirect ownership and identify the person who is the ultimate beneficial owner.
The goal is to ensure full transparency and clarity in the ownership structure.
What is an information update?
Master data is important for any business cooperation, including your dealings with the bank. If there is a change in your master data, you should let us know. We call it information update, and the master data is the name used for general information – business name, address or headquarters, name and surname of the beneficial owner / founder / legal representative or classification according to the National Classification of Activities (NKD).
Why do we collect your data?
Erste Bank, like all financial institutions in Croatia, has an obligation to update their clients' data in accordance with the Law on the Prevention of Money Laundering and Terrorist Financing (OG 108/17, 39/19), the General Tax Code (OG 115/16, 106/18, 121/19, 32/20, 42/20) and the Administrative Cooperation Act (OG 115/16, 130/17, 106/18, 121/19). Also, pursuant to the business cooperation agreement you have entered into with Erste Bank, you are required to update your master data.
By updating your business entity’s data, we jointly participate in the application of these laws on the Croatian financial market, and thus create the conditions for safe business operations.
How can we update your data?
We may update some data independently, without your confirmation*
Since we have ensured that the data is aligned with publicly available registers, we can independently update any changes relating to:
- Business entity name
- Classification according to the National Classification of Activities (NKD)
- Headquarters
- Legal form.
Each time we reconcile data from publicly available registers, we will send you a notification on compliant data.
We need you to update some of the data
Without your initiative, we cannot change:
- Contact address you have confirmed to us as valid for dealings with the bank
- Information relating to the change of the beneficial owner/founder/legal representative.
In order to update this information, the authorized person in your business entity** should submit to us – to a bank branch or financial representative – the following:
- Documentation confirming changed data and
- Request for changes in a transaction account (Zahtjev za izmjenu po transakcijskom računu).
Modification request can be found here.
As soon as there is a change in the master data, you should inform us about it. If we notice in publicly available registers that there has been a change in data that we cannot update independently, we will send you a memo informing you that we have noticed a change in the data and ask you to provide us with the necessary documentation.* It is really important that you pay attention to such a memo, since it will highlight the deadlines to be observed.
It is also important that you inform us when changing your phone number and email, so that we can always ensure timely communication.
* Valid for clients registered in the Court Register (Sudski registar), the Register of Associations (Registar udruga) and the Trades Register (Obrtni registar). Clients who are not registered in any of the above registers are obliged to update their data with Erste Bank immediately after the changes have been made.
** Assignee or procurator of a business entity is not considered a person authorized to represent the company in this process.
What does the master data update enable us to do?
By updating the master data in a timely manner, we will be able to continue our business cooperation – you will still be able to use the contracted products and services of Erste Bank unhindered and use the funds on your account.
For more information about updating the information, you can contact your financial representative, call us at 0800 7890 or email us at erstebank@erstebank.hr.