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.

Organised legal documents and a fountain pen on a dark indigo-toned surface

What compliance work actually covers

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.

Compliance services we provide

Specific work, not vague assurances.

KYC packaging

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.

Economic substance review

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.

FATCA and CRS guidance

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.

Annual compliance calendar

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.

Compliance questions we hear often

What is economic substance and why does it matter?

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.

How do FATCA and CRS affect my structure?

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.

Can you handle compliance if I already have an accountant?

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.

What happens if my compliance is already behind?

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

When did you last audit your compliance position?

If the answer is 'not recently', a review is the right starting point.

Request a compliance review