Intermediaries & Payments

Commissions must explain the service, the transaction and the payment

A commission is not “clean” because it has an invoice. The economic service, authority, underlying transaction, payee and traceability must align.

Professional broker vs occasional facilitator

1

Professional broker

Recurring professional activity and track record.
Contracts, invoices, clients and traceability.
Coherent accounts and tax treatment.

2

Occasional facilitator

One-off or exceptional transaction.
No relevant track record.
Extraordinary income inconsistent with ordinary activity.

Minimum evidence package

Contract / introducer agreement / mandate.
Invoice and commission calculation.
Underlying transaction and identity of parties.
Evidence of service and payment traceability.
Tax documentation and SoF where applicable.

A professional history may make the income more explainable. It does not exempt AML, KYC/KYB, sanctions, tax, SoF or transaction monitoring.