Beneficial owners

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Scope

As part of the verification process, certain legal entities are required by AML legislation to disclose their beneficial owners (also known as ultimate beneficial owners, or UBOs).

Mangopay needs to know who really profits from the entity to be able to properly assess risk and help prevent financial crime.

A declaration of beneficial ownership is always required to verify legal users of the types:

• Business
• Partnership

The declaration is not required for other types of legal users (nor for natural users).

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Declaration

The declaration consists of two parts:

• Information about all beneficial owners (see the glossary for a complete definition)
• Documents providing evidence for the declaration

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Required information

For each beneficial owner, the following information must be provided:

• First name
• Last name
• Date of birth
• Country of birth
• City of birth
• Nationality
• Address

The information for all beneficial owners must be provided via the API with the UBO declaration endpoints:

How to

Learn how to submit a UBO Declaration

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Documentary evidence

The information submitted about the beneficial owners is checked against the user’s verification documents, notably the registration proof and articles of association.

If the verification documents do not provide sufficient information about the beneficial owners, then a sworn statement may be requested to complete the declaration. This document, called the Shareholder Declaration, is a Mangopay form which must be completed and signed by the legal representative of the legal user.

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Process

The process for declaring beneficial ownership can be broken down into the following steps:

The response from Mangopay is indicated in the Status of the UBO Declaration object:

• VALIDATED - The UBO Declaration is validated by Mangopay.
• INCOMPLETE - The UBO Declaration is deemed incomplete by Mangopay. The object can be modified to complete the declaration.
• REFUSED - The UBO Declaration is rejected by Mangopay. The object can’t be modified and must be recreated to be submitted.

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In case of refused or incomplete declaration

For incomplete or refused declarations, you can learn more about the reasons for refusal in the Reason and Message parameters.

The following table describes the Reason values about why the UBO Declaration was marked REFUSED or INCOMPLETE. Ensure you check the Message parameter for personalized information from Mangopay’s teams.

Reason	Issue	Recommendation
MISSING_UBO	One or more beneficial owners are missing from the declaration. For example, in the verification documents 2 individuals are indicated as owning more than 25%, but only one appears as a UBO in the UBO Declaration object.	Check your calculations of who is a beneficial owner and ensure that they are each present as UBOs in the UBO Declaration. See the glossary for more information about who is considered a beneficial owner.
WRONG_UBO_INFORMATION	One or more of the parameters for the object’s UBOs has been incorrectly entered.	Review the information for the UBOs and ensure it is consistent with the verification documents.
UBO_IDENTITY_NEEDED	We need a proof of identity document for a beneficial owner.	Submit an accepted identity document for the beneficial owner as a KYC Document and then resubmit the declaration.
SHAREHOLDERS_DECLARATION_NEEDED	The articles of association do not give sufficient information about the beneficial owners, so we can’t verify the information in the object. We need the Shareholder Declaration completed and signed by the legal representative.	Complete and sign the Shareholder Declaration form and submit it as a KYC Document before re-submitting the declaration.
ORGANIZATION_CHART_NEEDED	The business structure is complex and we need a chart which clarifies the relationship between holding entities (i.e., an organigramme or organizational chart).	Submit the requested supporting document as a KYC Document. Check the Message parameter for more details.
DOCUMENTS_NEEDED	We don’t have sufficient documentary evidence to validate the declaration.	Submit the requested supporting document as a KYC Document. Check the Message parameter for more details.
DECLARATION_DO_NOT_MATCH_UBO_INFORMATION	The UBO Declaration object doesn’t match the information we have obtained on the beneficial owners from the verification documents. This may be the case if a Shareholder Declaration form has been completed and validated but the UBO Declaration has not been subsequently updated, meaning the two are inconsistent.	Ensure the information in the UBO Declaration is fully consistent with the verification documents (including the Shareholder Declaration).
SPECIFIC_CASE	There is a specific reason for the rejection in this case.	Check the Message parameter for more details.