[Early Access] New Business Onboarding Requirement

There is a new mandatory field in the business member object - "designation" - which defines the official role of the member in the business. Each business member must have this field set before KYB submission.

Each business needs to have one control person. The programs can use the isControlPerson flag in the business member object to set a member as the control person. The programs must explicitly ask through their application if the business member being added is the control person or not. When the program designates a business member as a control person by setting the "isControlPerson" field to true, and a control person already exists, the previously assigned member will no longer be considered a control person, and this flag isControlPerson will be overriden for the previous assigned person.

The control person must have one of the designations from the list below:

chiefExecutiveOfficer
chiefFinancialOfficer
chiefOperatingOfficer
chiefLegalOfficer
generalCounsel
managingMember
member
generalPartner
managingPartner
partner
president
executiveVicePresident
vicePresident
treasurer
comptroller
managingDirector
chairmanOfTheBoardOfDirectors

For other members of a business that are not the control person, the designation can be set to any of the full list of allowed designations found here.

Impact

The Submit KYB API will return the following error if none of the business members are the control person. Please make sure there is one control person before KYB submission:

1. {
2.   "requestId": "req-abff1926-bffa-4984-9a44-f006d45043c6",
     "method": "POST",
3.   "status": 400,
4.   "code": "EC_BUSINESS_MISSING_CONTROL_PERSON",
5.   "message": "Business must have a control person",
6.   "sysMessage": "",
7.   "programId": "prg-58465921-2d40-49fa-9418-ccb76f4b9129",
8.   "env": "v2-prod-live",
9.   "createdAt": "2023-11-22T12:08:02Z"
10. }

The Submit KYB API will return will return the following error if any business members doesn’t have the designation field set:

1. {
2.   "requestId": "req-abff1926-bffa-4984-9a44-f006d45043c6",
3.   "method": "POST",
4.   "status": 400,
5.   "code": "EC_BUSINESS_MEMBER_MISSING_DESIGNATION",
6.   "message": "Business member designation is mandatory",
7.   "sysMessage": "",
8.   "programId": "prg-58465921-2d40-49fa-9418-ccb76f4b9129",
9.   "env": "v2-prod-live",
10.   "createdAt": "2023-11-22T12:08:02Z"
11. }

The create business member and update business member endpoints will return the following error if the control person designation doesn’t belong to the list of designations shared above:

1. {
2.   "requestId": "req-abff1926-bffa-4984-9a44-f006d45043c6",
3.   "method": "POST",
4.   "status": 400,
5.   "code": "EC_BUSINESS_MEMBER_INVALID_DESIGNATION",
6.   "message": "Business control person designation is invalid",
7.   "sysMessage": "",
8.   "programId": "prg-58465921-2d40-49fa-9418-ccb76f4b9129",
9.   "env": "v2-prod-live",
10.   "createdAt": "2023-11-22T12:08:02Z"
11. }

API Changes

The programs can pass the “designation” field in the business member create and update endpoints. Below is a sample request:

1. {
2.  .. 
3.   “designation”: “chiefExecutiveOfficer”,
4.  .. 
5. }

There must be one control person in a business. The programs can pass "isControlPerson" flag as true in the business member create and update endpoints if the business member being added is a control person.

Business Onboarding Flow

Below is the recommended approach for business onboarding:

1. Use the Create a Business API to create a business.

2. Add members to the business using the create business member and update business member endpoints by enforcing control person and designation validations mentioned above.

Note: This step can be skipped if the business "entityType" is "Sole Proprietor".

3. The business owner needs to sign the business ownership disclosure. Use the Business Ownership Disclosure API.

4. The program then submits the business for KYB using the Submit a KYB API.

5. If you need to make any changes to the business owner after the signing of the ownership disclosure document, the document needs to be re-signed before KYB submission, using the "action": "regenerate" command in the Business Ownership Disclosure API.

Important date

02/15/2024: Any business KYB submitted without business member designation or control person will return the above-mentioned error.