Beneficial owners | Mangopay docs

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).

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

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

Documentary evidence

The information submitted about the beneficial owners is checked against the Legal User’s KYB 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 declared legal representative of the legal user. The Shareholder Declaration should only be provided if requested by Mangopay and is available here in multiple languages.

Process

Note - Submit verification documents before UBO Declaration

Because the information in the UBO Declaration is compared with the verification documents, it is necessary to submit all the required documents first before submitting the UBO Declaration.

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

Submission

The platform collects and submits information via the UBO Declaration object for the legal user.

Verification

Mangopay’s teams check the declaration against the verification documents submitted.

Complementary details (if necessary)

Depending on the response from Mangopay, the platform provides complementary documents or information for the legal user. The UBO Declaration may need to be resubmitted to ensure that it is consistent with the validated documents.

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.

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.

Note - Only INCOMPLETE objects can be modified and resubmitted

If the object status is INCOMPLETE, the same UBO Declaration object can be modified and resubmitted. If the status is REFUSED, a new UBO Declaration object needs to be created (if relevant following the response).

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 Registration Proof and/or Articles of Association do not give sufficient information about the beneficial owners, so we can’t verify the information in the UBO Declaration 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 (`SHAREHOLDER_DECLARATION` type) 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 organigram or organizational chart).	Submit the requested supporting document as a KYC Document (`SHAREHOLDER_DECLARATION` type). 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). If any individuals have been added as UBOs that should not be considered as beneficial owners, disregard them by setting `IsActive` to `false` using the PUT Update a UBO endpoint or the Dashboard.
`SPECIFIC_CASE`	There is a specific reason for the rejection in this case.	Check the `Message` parameter for more details.