Background information
Why is Mangopay implementing the identity verification renewal process now?
Validating user identities is essential for maintaining the integrity of the platform’s user base and preventing fraud. Regulators require this process as part of their anti-money laundering (AML) requirements. As a Payment Service Provider (PSP), Mangopay ensures clients follow Customer Due Diligence (CDD) guidelines. Historically, we performed identity verification only once during a user’s lifecycle, along with continuous screening, but did not trigger identity verification renewals for end users. The CSSF (Comité de Surveillance du Secteur Financier) revised its guidelines and now requires PSPs and their clients to adhere to new rules:- Risk-based approach: Adopting a risk-based approach to CDD, adjusting the level of scrutiny according to the customer’s risk profile.
- Reviewing existing users: Conducting CDD not only when establishing business relationships but also during regular reviews of existing users.
- Keeping records up to date: Maintaining updated records of all CDD measures and any factors influencing risk assessments.
- Emerging risks: Considering and incorporating emerging risks into assessments necessitating ongoing verification.
What are the benefits of renewing users’ identity verification?
The identity verification renewal brings benefits, including a cleaned database with up-to-date user information, reduced risk of fraud by helping prevent criminal activity and compliant user information that will minimize service disruptions, helping to maintain a positive customer experience. Identity verification renewal offers several advantages:- Reduced Fraud: Updated customer information helps prevent fraudulent activity.
- Regulatory Compliance: Ensures your business adheres to financial regulations, avoiding penalties.
- Improved Customer Trust: Demonstrates your commitment to security and data accuracy.
- Seamless Service: Minimizes account restrictions or disruptions due to outdated information.
How are users be selected for renewal?
We are targeting based on user risk, but due to confidentiality and regulatory requirements, we are unable to disclose more information.Pricing
Will there be any costs associated with the identity verification renewal process?
Like the initial identity verification process, identity verification renewal has associated costs. We will charge the same rates as your initial identity verification verification. This is a standard regulatory requirement to ensure all user information is up-to-date and accurate.Will identity verification renewal charges appear as a separate line item on our invoice, or will they be included with the initial identity verification charges?
Identity verification renewals will not appear as a separate line item on your invoice; they will be integrated with the initial identity verification charges. However, to help you measure the impact of identity verification renewals, we can provide you with a detailed list of users who have undergone the identity verification renewal process. Please contact us to request this information.How many of your users will be impacted, and require identity verification renewal?
This does not apply to all your users, only to those whose identity documents have expired. We have identified the specific users affected, and you will be provided with a personalized list of those requiring identity verification renewal.Support
Where can I find technical documentation on the identity verification renewal and general identity verification process for Mangopay?
The KYC renewal guide outlines the process for re-verifying the identity of existing Mangopay users to comply with anti-money laundering (AML) regulations.Should our end-users contact Mangopay or our support team if they have queries?
If your end-users have queries about their identity verification process, they should always contact your support team first. You’re best equipped to guide them through your specific platform’s user experience and address any issues related to document uploads or general questions. At Mangopay, our role is to provide identity verification services and support you, the marketplace, in managing your users’ verification process. If your team encounters any technical difficulties or has questions about our identity verification solutions, we’re here to help! However, we do not directly answer support questions from your end-users. By maintaining this structure, we can ensure a seamless experience for your users and efficient resolution of any KYC-related challenges.How can I get further support?
You can get further support by contacting the support team directly via the dashboard.Process
What is the timeline for this project?
The timeline for this project will be outlined in the communications you received and will vary based on user type and platform. Please adhere to the dates outlined in your original email.What happens if our users can’t proceed with their identity verification renewal or if they don’t send new documents?
If your users do not complete identity verification renewal by the date specified in our email, they will be downgraded and unable to access key services like payouts. Once downgraded, and within the communicated timelines, the user will also have pay-ins and transfers blocked as well as payouts.Why are a user’s pay-ins and transfers blocked?
Pay-ins and transfers are blocked because the user has not completed the mandatory KYC verification renewal (re-KYC) process, which is required to ensure regulatory compliance and maintain security on your platform.How can users regain access?
Users can regain access immediately after completing their Re-KYC by submitting the required identification documents (such as a passport, driving license, or national ID card for individuals, and identity/registration documents for businesses). The list of users that were subject to renewal, and therefore subject to downgrading and transaction refusals, was shared with your platform in the Mangopay Dashboard.Will users regain their status if they are downgraded and complete identity verification renewal?
Yes, once they complete a identity verification check, they will be able to regain access to all services.The KYC renewal guide explains which notifications you will receive once the check has been completed.How can we distinguish between a standard identity verification process and a identity verification renewal in the Mangopay Dashboard?
Currently, the Mangopay Dashboard does not differentiate between standard identity verification and identity verification renewals. To track renewals, please contact your Account Manager or our support team for a list of users who have undergone identity verification renewal, allowing you to monitor their status.How should users be notified about their downgraded status, and who is responsible for this notification?
The process of notifying end users rests with the platforms. However, we have prepared an email template that platforms can send to users to communicate effectively, highlighting the benefits and necessity of this process for their users. Here’s a suggested approach:- Transparency: Clearly explain the reason for the downgrade, emphasizing that this step is part of an ongoing effort to enhance security and protect users from potential fraud.
- Benefits: Highlight the benefits of the identity verification renewal process, such as increased security, fraud prevention, and ensuring a safe and reliable platform for all users.
- Instructions: Provide clear and concise instructions on what users must do to complete the identity verification renewal process and restore their full access to the platform.
- Support: Provide support and assistance throughout the identity verification renewal process, ensuring users know they can reach out to your support team with any questions or need any help.
How can we ensure the identity verification renewal process is handled correctly?
You must follow the KYC renewal guide to ensure a seamless user experience for your users.If end-users update their identity verification documents before being downgraded, how will Mangopay handle this?
Platforms have received an initial email with a list of users who must renew their identity verification within a two-month period. Before running the downgrade script, we will update this list to exclude users who have completed the renewal. Only those from the initial list who have not completed the identity verification renewal will be included in the final list of accounts to be downgraded.Will identity verification renewal be a one-off event?
Identity verification renewal will be a continuous process. We understand that asking a large number of users to complete identity verification renewal at once may be difficult, and we thank you for your understanding. Going forward, new users will be part of a continuous renewal process, ensuring regular and timely identity verification renewal checks.How do we know if an identity verification renewal has been completed?
You can check that a identity verification check has been completed by configuring the following webhooks to receive alerts when identity verification document statuses change:- Listen for the
KYC_SUCCEEDEDevent to know when a document is successfully validated. - Listen for the
KYC_FAILEDevent to be notified of document rejections.
Do identity verification renewal requirements differ between countries like the UK and France?
Identity verification requirements vary by country, but we will ensure compliance with all relevant regulations. For more information, see the requirements article.For future identity verification renewals, will we be notified when a identity verification is due for renewal, and what actions are required?
We are devising a solution and will notify you of a long term solution which will aim to automate the process.How long will the identity verification renewal process take for end-users?
The identity verification renewal process is designed to be quick and efficient for your end-users. While our Service Level Agreements (SLAs) aim to verify Natural User documents within 24 hours, we anticipate that the majority will be completed in a shorter timeframe. The renewal process itself will be similar to the initial identity verification process your users are already familiar with. This should help minimise any confusion and ensure a smooth experience.Which documents and information are needed to perform the identity verification renewal for a user?
These are the mandatory document types required for the renewal process:Natural
- Identity proof of the user
Legal - Business
- Identity proof of the legal representative
- Registration proof dated within the last 3 months
- Articles of association – the latest version, signed and up to date
Note – Declaring beneficial owners in renewalThe UBO Declaration and Shareholder Declaration may be requested if there has been a change in the shareholding structure since the previous identity verification.For the identity verification renewal, these elements are not mandatory by default.
Legal - Organization
- Identity proof of the legal representative
- Registration proof dated within the last 3 months
- Articles of association – the latest version, signed and up to date
Legal - Soletrader
- Identity proof of the legal representative
- Registration proof dated within the last 3 months