KYC downgrade process

KYC documents (Identify Proof, Articles of Association, Registration Proof, and Shareholder Declaration) are used to validate the information a user has submitted to the platform, including banking details.

If a user’s identity profile is changed after validation of KYC documents, those KYC documents will no longer be relevant, as what is being validated will have changed. The status of impacted documents will change from 'VALIDATED' to 'OUT_OF_DATE'.

Should any KYC documents have the status 'OUT_OF_DATE' then the user will not fulfill the requirements to be 'KYC Regular' validated.

As such, if key profile information is changed for a KYC validated user, that user will be downgraded from 'KYC Regular' to 'KYC Light' verification status. This will limit the actions that a user can undertake as per AML5 regulations.

Please refer to the following section for further information about KYC limits https://docs.mangopay.com/guide/kyclimits

Scenario

The following is a use case of when a KYC document downgrade occurs:

1. User modifies personal information on the platform
2. All documents submitted by the user will pass from VALIDATED status to OUT_OF_DATE status
3. We will re-trigger the KYC calculation: if any of the required documents are missing or do not have VALIDATED status, then the KYC level will be downgraded from KYC Regular to KYC Light.

Relevant Fields

Changes to the following information fields, after KYC validation, will result in an automatic downgrade to Light (default) verification.


Natural user:

FirstName
LastName
Birthday
Nationality

Legal user (all types – business, soletrader, organization):

LegalRepresentativeFirstName
LegalRepresentativeLastName
LegalRepresentativeBirthday
LegalRepresentativeNationality

Please note: This downgrade will also apply if the user has been validated with the inverse information for FirstName and LastName and the user profile is then subsequently altered.

User category:

Switching the UserCategory value from “Payer” to “Owner” will result in an automatic downgrade to Light (default) verification as well. Please refer to the User Verification article for more information regarding verification and user categories.

Notifications

Hooks are available to provide notification of when a user has lost its KYC status for an identity change reason.

USER_KYC_LIGHT => USER_KYC_LIGHT will warn the client that a user's KYC verification level has been downgraded to 'KYC Light'

KYC_OUTDATED => it will warn the client that for one of its user, a document’s status has been changed to OUT_OF_DATE

USER_KYC_REGULAR => USER_KYC_REGULAR will warn the client that a user has been KYC validated

Example of USER_KYC_LIGHT hook subscription:

Note this hook functions normally, as per all other MANGOPAY hooks.

Notification will be sent to the designated URL should a user be downgraded to 'KYC Light' status:

your-site.com?EventType=USER_KYC_LIGHT&RessourceId=Id&Date=Timestamp

Note: The Id is that of the User

The creation of this Hook is as follows:

{

        "EventType": "USER_KYC_LIGHT",
        "Url": "http://www.test.com"

}

Please refer to the Hooks section of this documentation for further information.

Upgrading KYC status

Should an end user lose their KYC validation due to a document being marked as OUT_OF_DATE. The user will need to resubmit new documents, and these to be validated, in order to regain the 'KYC Regular' verification.

Please refer to the User Verification section of this documentation for further information.