Coming soon: All legal reps and UBOs verified
In the coming months, Mangopay will be introducing liveness checks for all legal representatives and beneficial owners (UBOs) of Businesses (and all legal representatives in the case of Organizations). The liveness check will be delivered by Mangopay via email, thanks to the email address entered by the Legal User in the hosted IDV session. The main IDV Session will be separated from the sub-sessions for liveness checks, allowing a granular approach to completing the process. When all required individuals have successfully completed the liveness check, the entity will be verified (KYCLevel will become REGULAR).
To fulfill this requirement, Mangopay’s hosted KYC/KYB solution will:
- Allow a Legal User to provide email addresses for legal representatives and beneficial owners
- Facilitate data submission through registry lookups
- Provide features for your platform to have visibility over the progress of verification sessions and email communications with the individuals involved
Will all individuals listed in public registries need to be verified?
Not necessarily. In cases where tens of individuals are listed, not all of them will need to be verified. Mangopay is taking a pragmatic risk-based approach to optimize Legal User onboarding in full compliance. Additionally, the criteria by which Mangopay defines a beneficial owner is not changing – this is typically individuals ultimately owning 25% or more, whether directly or through holding companies (see full description here). It is possible that the percentage threshold will be tightened for a given Legal User based on Mangopay’s risk assessment.Prerequisites
Before launching a hosted IDV Session for a Business, please ensure that:- The Registration Proof they will need to upload conforms to the one expected by Mangopay
- The Articles of Association they may need to upload conforms to the one expected by Mangopay
- They have details about their business and all beneficial owners (definition here)
- An individual listed in the national registry is available to perform the liveness check (the link can be closed and reopened)
- The ID proof the individual will use is accepted by Mangopay
Flow description
Currently, when a hosted IDV session is generated for a Legal Business:- The session
StatusisPENDINGand is valid for 24 hours - The user opens the session and sees a welcome screen explaining:
- That they will need to provide business details
- That they may need to provide Registration Proof (RP) and Articles of Association (AoA) documents (links to the KYB local page are provided later in the flow)
- That a registered director (not necessarily the one listed in the
LegalRepresentativefields) will need to complete the liveness check with their ID and smartphone, with a link to Mangopay’s accepted ID documents
- The user enters business details:
- Country of incorporation
- Registration number provided by the relevant national authority
- Registered business name
- Registered business address
- The user declares one or more as
- Mangopay performs registry lookup using the business details:
BUSINESS_VERIFICATION
- There are two possible outcomes from the registry lookup:
- There is a match. In this case, the user must upload an accepted Registration Proof.
- There is no match. In this case, the user must upload an accepted Registration Proof and Articles of Association, and the session is sent for manual review (
Statuswill beREVIEW).
- The session must then be opened by the registered director who will complete the liveness check (the session autosaves progress)
- The registered director completes the liveness ID check (via QR code or directly if session opened on a phone) by:
- Taking a photo of their ID (or two photos if it’s a driver’s license or national ID card)
- Taking a selfie of their face
- The session is redirected to the
ReturnUrl - Mangopay performs automated liveness validation checks:
IDENTITY_DOCUMENT_VERIFICATIONIDV_AGE_CHECK
- If successful, Mangopay checks that the individual in the ID is listed in the registry (
BUSINESS_INSIGHTS_MATCH).- If successful, the session’s status becomes
VALIDATED - If unsuccessful, the session is reviewed manually (
REVIEW) before the final outcome
- If successful, the session’s status becomes
Checks performed
Currently, for Legal Business Users, the following checks are performed in the order listed:| Type | Description |
|---|---|
BUSINESS_VERIFICATION | Uses the business name and registration number (or tax number) entered by the user in the session to attempt a lookup in the national business registry. If not successful, the user is asked to upload the Articles of Association in addition to the Registration Proof and the session status will necessarily be REVIEW. |
IDENTITY_DOCUMENT_VERIFICATION | Verifies the authenticity of the identity document, the liveness of the selfie, and that the selfie matches the identity document photo. |
IDV_AGE_CHECK | Checks whether the individual on the identity document meets the minimum age requirement for Mangopay users (age 18). Only performed if IDENTITY_DOCUMENT_VERIFICATION is successful. |
BUSINESS_INSIGHTS_MATCH | Checks whether the name on the ID document matches one of the directors listed in the national registry. Performed manually if BUSINESS_VERIFICATION is unsuccessful. |
Outcomes
For a Business user, the following outcomes are possible (from aPENDING status):
Automated validation
TheStatus becomes VALIDATED if all automated checks performed were successful. In this case:
- The verified data is overwritten in the User object:
LegalRepresentative.FirstName(even if the fields previously referenced a different individual)LegalRepresentative.LastNameLegalRepresentative.BirthdayCompanyNameCompanyNumber
- The User’s
KYCLevelbecomesREGULAR
Automated refusal
TheStatus becomes REFUSED if any of these checks fail:
IDENTITY_DOCUMENT_VERIFICATIONIDV_AGE_CHECK
- You can retrieve more information in the IDV Session’s:
Checks.CheckStatus- For which checks wereREFUSEDChecks.Reasons– For the refusal reasons (Typeand presetValue)
- You need to generate a new session to retry (even if some of the checks were validated)
Manual review
Provided theIDENTITY_DOCUMENT_VERIFICATION and IDV_AGE_CHECK are successful, the Status becomes REVIEW if either of the following checks fail:
BUSINESS_VERIFICATIONBUSINESS_INSIGHTS_MATCH
- Mangopay reviews the session data and documents manually.
- The
Checks.CheckStatusshows which checks wereREFUSEDand triggered the manual review - Automatically validated checks are returned, including verified data, but the User object data is only overwritten if the session is validated
Validation after review
If the manual review is successful, theStatus changes from REVIEW to VALIDATED. In this case:
- The verified data is overwritten in the User object:
LegalRepresentative.FirstName(even if the fields previously referenced a different individual)LegalRepresentative.LastNameLegalRepresentative.BirthdayNameCompanyNumber
- The User’s
KYCLevelbecomesREGULAR
Refusal after review
If the manual review is unsuccessful, then the status changes toREFUSED.
In this case:
- Verified data may be returned in the IDV Session but no action is taken with it
- You can retrieve more information in the IDV Session’s:
Checks.CheckStatus- For which checks wereREFUSEDChecks.Reasons– For the refusal reasons –Typeand, in the case of a manual review, a custom message in theValue
- You need to generate a new session to retry (even if some of the checks were validated)