Compliance
Compliance isn't bureaucracy — it's what keeps your structure standing
An offshore structure that is technically correct but practically non-compliant is the most expensive kind. We make sure yours is both.
Compliance
An offshore structure that is technically correct but practically non-compliant is the most expensive kind. We make sure yours is both.
Compliance for offshore structures spans several distinct obligations, and they rarely arrive on the same schedule. There is the KYC documentation you provide to banks and service providers — which needs to stay current and internally consistent. There is economic substance: demonstrating that your entity has genuine presence and decision-making activity in its jurisdiction of incorporation, not merely a registered address. There is FATCA and CRS reporting, which requires your structure to be correctly classified and for the right disclosures to reach the right tax authorities in the right format. And there is the annual maintenance cycle of filings, renewals, and audits that keep the entity in good standing. Missing any of these is rarely catastrophic on day one, but cumulative gaps compound into situations that are expensive and time-consuming to resolve — and that attract the kind of attention that defeats the purpose of the structure in the first place.
Specific work, not vague assurances.
We assemble and format your KYC documentation to the standards of the relevant jurisdiction and institution, including certified copies, apostilles where required, source-of-funds narratives, and beneficial ownership declarations.
We assess your entity's current substance position against the requirements of its jurisdiction, identify gaps, and recommend practical steps to close them — including board meeting protocols, local director arrangements, and expenditure evidence.
We help you understand your entity's classification under FATCA and CRS, identify which accounts and structures are reportable, and work with your accountants to ensure the reporting process is accurate and on time.
A jurisdiction-by-jurisdiction filing and renewal schedule, updated annually, with reminders ahead of each deadline. We also coordinate with your registered agents to confirm filings are submitted rather than merely scheduled.
Economic substance rules require offshore entities to demonstrate that their core income-generating activities are actually managed and directed from within their jurisdiction of incorporation — not merely registered there. Failing a substance test can result in penalties, automatic exchange of information with your home jurisdiction's tax authority, and in some cases loss of the entity's tax status entirely.
FATCA is a US regime; CRS is a multilateral OECD framework that over 110 countries participate in, including Kenya. Both require financial institutions to identify and report accounts held by foreign tax residents. If your structure is not correctly classified or reported, you face penalties in the relevant jurisdictions — and the discrepancy is often what triggers an audit.
Yes — we work alongside existing accountants regularly. Our compliance work is specific to the offshore structure: KYC, substance, and the mechanics of the entity itself. Your accountant typically handles the home-jurisdiction tax returns and group reporting. We produce documentation that makes their job simpler, not duplicative.
We can assess the current position, identify the most urgent gaps, and develop a remediation plan. Getting back into good standing is almost always possible, though the cost of correction rises the longer the gaps remain open. We will be direct about what is involved and realistic about timelines.
“Our registered agent had been sending us annual filing reminders for two years that we had not fully understood. Lumenvstone audited the full compliance position in three weeks, found a substance issue that our agent had not flagged, and had it resolved before our banking relationship review. I would not have known to look.”
Samuel T., Mombasa — trading group CFO
If the answer is 'not recently', a review is the right starting point.