u/Buttonman88

I’m not posting this here to detail my ongoing infuriating woes with Trading212 over the last month regarding AML/KYC (Anti-Money Laundering/Know Your Customer: ID Verification). I’m really just going to make some observations, principally directed at any Trading212 personnel seeing this.

Ofc, please anyone weigh in to agree/refute/add to the topic. It’s kind of applicable to most banks and fintech in EU these days given how restrictive and invasive their AML protocols have become for *every genuine customer*, usually ‘the little ppl’ who’re made to jump through hoops for their few pennies service in order to thwart the big operator genuine launderers who probably have the means, network and savvy to disperse millions through those same systems without raising even one red flag.

So, Trading212…. some personal on-the-ground observations about your customers and how *I* see you see/service them…

1.
You seem to think a legit customer is someone who lives in one territory, maintains one source of trading funds and banks locally for the entire time they trade with you.
In the real world, people often have multiple legitimate sources of income and, especially in the EU, mobile citizens may hold savings in multiple allowable countries, from different sources of earning, even maybe earned and held outside EU borders. I personally have 5 banks in 5 different countries in the EU and another 4 outside, all necessitated by my international work situation over time. None are ‘cowboy’ banks. Chinese banks would even put EU standards of deposit checking to shame with their stringency and oversight.
Yet, Trading212’s financial profile allows only ONE country source of funds, ONE means of earning and ONE set of financial bands. Newbies can’t specify SALARY + SAVINGS when they sign up, let alone SALARY UK + SAVINGS USA/UK. I imagine people just enter their honest current salary situation at registration and then forget about it until years later they decide to put some nest egg to work and suddenly they’re red flagged for. And if they conscientiously chose to update their profile BEFORE depositing, Trading212’s EITHER/OR form forces them to omit something to include something, making their new declaration a technical misrepresentation  of the facts.
T212, your setup is making honest customers look suspicious because they’re trying to be transparent but you don’t allow them to be complete. So they get flagged if they don’t update; they get flagged if they abruptly do!

2.
You seem to think that people hold records of everything for their entire lives so that they can present hard evidence for everything they ever did/do related to their wealth.
Actually, in China and Japan, they do!
But in the real EU world, not everyone has pay-slips going back 30 years handy when they finally decide to dump that 30 year old nest egg into a stock portfolio. Mobile workers especially might not even get pay-slips from some international territories even today. They might be lucky to grab a tax record on their way to exit that country. Their employer from 20 years ago might be shuttered now. Their overseas bank might not provide statements that far back in their current apps or portals. I’m not talking about dodgy cash jobs; I mean legit work with salaries direct-deposited, banked and already locally audited.
T212 really needs a more complete, flexible approach to evidentiary documents because not every legit penny has a uniform paper trail that conforms to its current generic criteria; just as uniform paper trails can and usually do exist for actual laundered money.

3.
You seem to think that everyone is either a homeowner or a renter in their country and that they all operate their residences in the same generic way. In your incorrect worldview…

• all renters register all utilities under their own name;
• everyone maintains a fixed main residence or at least a  tie to a family residence;
• no one spends any length of time moving for their work so as to negate the need for long-term living arrangements;
• no one ever takes extended time away to just ‘be’ and ‘chill’, or travel the world for a year;
• no one uses a VPN;
• no one uses a top-up phone;
• everyone has a home internet provider. I could go on

Everyone’s different T212. Try to be open to that during your KYC checks.

4.
And this one was new to me, even after a year on the platform.
You need to tell customers on sign-up about the Fund/Withdraw restriction that ties money-in sources to money-out destinations and amounts. I had no idea, because actual banks don’t operate this way. I can deposit to my Revolut from any source and transfer it onwards to any source, NQA, within reason. YOUR WAY MAKES NO SENSE TBH. If I fund T212 from 2x EU Banks A & B (both compliant and verified by T212), how in god’s name is it foiling the money launders that I am not allowed to withdraw my entire T212 holding to only the one preferred receiving bank? Had I known that you operate this rule (unique to you, it seems), it would have drastically altered how I funded my account in the first place. I doubt many long-game customers even realize this if they haven’t ever tried to withdraw funds. Spoiler alert guys!

Rant over. I know banks/fintech are obligated to conduct AML and KYC checks. I get it! But T212, you make it so much harder on honest customers by the restrictive rigidity of your IT systems and the anal intensity of your requirements when flags are raised. If you want less red-flagged customers…

Be more transparent, flexible and upfront with new customers during registration so they know how to avoid nasty complications further down the line. They’ll be better informed how they can/should/can’t fund and realize their account and what documentation they should keep on record on an ongoing basis to avoid future scrutiny when they trading habits change.

And be more flexible and accommodating about recognizing and dealing with customer situations outside the normal parameters of vanilla John/Jane Citizen. There’s no one-size-fits-all unless you want it. And if you want it, say so during sign-up and save yourself (and us weirdoes) the trouble and time.

Peace!