Introduction
The KYC/KYB verification process consists in verifying the information a user declares against official documents, like a passport. In the case of Mangopay’s hosted verification session there is also a liveness check. Once their documents have been validated as being authentic and consistent with the individual’s data, the user is verified. In the API, the Natural User or Legal User is verified when theirKYCLevel changes from LIGHT to REGULAR.
However, if the user’s details subsequently change so they are no longer consistent with the documents, then the documents are no longer adequate proof.
In this case, Mangopay applies a downgrade mechanism to mark the relevant KYC Document or IDV Session objects as outdated.
Without the downgrade mechanism, a user could be verified under one name, then change their name, and then make to an external bank account in the altered name. This would present a clear risk of money laundering and terrorism financing.
What is downgraded
Mangopay offers two solutions that allow user’s to become KYC/KYB verified:- A hosted solution (using an IDV Session API object), where the user enters data on a Mangopay-hosted webpage (and uploads documents if a Legal User), and completes a liveness check using their ID
- An API-based solution (using one or more KYC Document API objects), where the user submits data and static document files on your platform
Status of these API objects changing to OUT_OF_DATE (same value on both IDV Sessions and KYC Documents).
Typically, the User’s KYCLevel changes simultaneously from REGULAR to LIGHT, indicating that they have lost their KYC/KYB verified status.
In the case of the KYC Document, an identity document can be downgraded after submission but before validation. In this case there is no change of verification level because the user was not verified before the downgrade.
Note - Downgraded sessions and documents must be resubmittedIf a user loses their KYC/KYB verified status as a result of the downgraded mechanism, they need to complete the IDV Session again or submit the relevant KYC Document again.They will be unable to exceed the KYC/KYB limits (e.g. request a payout) until they have regained verified status.
Relevant information fields
There are two scenarios in which the downgrade mechanism is applied.1. Change of identity details for natural persons
Natural user
If the following information is changed:FirstNameLastNameBirthdayNationality
- In the hosted solution, the
Statusof the IDV Session changes toOUT_OF_DATEif it was previouslyVALIDATED. - In the API-based solution, the
Statusof the KYC Document withTypeIDENTITY_PROOFchanges toOUT_OF_DATEif it was previouslyVALIDATEDorVALIDATION_ASKED.
Legal user
If the following information is changed regarding the declared individual representing the legal entity:LegalRepresentative.FirstNameLegalRepresentative.LastNameLegalRepresentative.BirthdayLegalRepresentative.Nationality
- In the hosted solution:
- The
Statusof the IDV Session changes toOUT_OF_DATEif it was previouslyVALIDATED.
- The
- In the API-based solution, the KYC Document
Statusvalues change depending on theType:- The
IDENTITY_PROOFstatus changes toOUT_OF_DATEif it was previouslyVALIDATEDorVALIDATION_ASKED. - The
REGISTRATION_PROOF,ARTICLES_OF_ASSOCIATION, andSHAREHOLDER_DECLARATION(as applicable) status changes toOUT_OF_DATEif it was previouslyVALIDATED.
- The
2. Change of legal entity type
Legal user
If the following information is changed:LegalPersonType
- In the hosted solution:
- The
Statusof the IDV Session changes toOUT_OF_DATEif it was previouslyVALIDATED.
- The
- In the API-based solution:
- The
REGISTRATION_PROOFdocument (only) changes toOUT_OF_DATEif it was previouslyVALIDATED.
- The
LegalPersonType.
Note - UBO Declaration not affected by downgradeThe information about beneficial owners provided via the UBO Declaration endpoint is not affected by the downgrade. However, the documents against which this information is verified - that is, the articles of association or the Shareholder Declaration signed by the legal representative - can be downgraded.
Notifications
Your platform should set up webhook notifications for the following event types to be notified when a downgrade occurs.- For Natural and Legal Users, the
USER_KYC_LIGHTevent indicates that theirKYCLevelchanged fromREGULARtoLIGHT, meaning that they have lost their KYC/KYB verified status. - For the hosted solution, the
IDENTITY_VERIFICATION_OUTDATEDevent indicates that the session’sStatuschanged toOUT_OF_DATE. - For the API-based solution, the
KYC_OUTDATEDevent indicates that the document’sStatuschanged toOUT_OF_DATE.