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BVNK

For business customers

This article provides a comprehensive summary of the required fields, document types, identity verification requirements, and applicable conditions for onboarding business customers (companies) to our platform.

To onboard a company to the BVNK platform, submit the following information.

Overview​

Requirements differ along two dimensions:

  • Jurisdiction: the BVNK entity that contracts with the customer:

    • US — System Pay Services (US), Inc., a Delaware-incorporated company (NMLS ID 2531294), registered as a Money Services Business with FinCEN and licensed as a money transmitter in various US states.
    • EU — System Pay Services (Malta) Ltd (C66961), authorised by the Malta Financial Services Authority (MFSA) as an Electronic Money Institution and as a Crypto-Asset Service Provider under MiCA (Regulation (EU) 2023/1114).
  • Onboarding model:

    • BVNK-Managed: you provide documents and structured data, BVNK performs ID&V.
    • Partner-managed: you perform ID&V and pass verification metadata + risk attestations to BVNK.

    The applicable onboarding model depends on the type of business and the licensing setup of the Embedded Partner. Contact the BVNK Solutions team to confirm which model applies to your integration.

For the technical integration, payload structures, and endpoint reference, see the Create business customers guide.

Legend

The tables on this page use the following symbols to indicate whether an item is required for each jurisdiction:

  • ✅: Required. You must always provide this item.
  • ☑️: Conditional. You must provide this item only when the conditions described in the table apply, for example, for US addresses, high-risk customers, or associates holding a specific role.
  • ❌: Not required. You don't need to provide this optional item for this jurisdiction.

Business entity information​

Company profile​

FieldUSEUValidation / why we collect it
Legal Entity Name
company.name
✅✅Verified against business registry records. Must match formation documents exactly.
Registration Number
company.registrationNumber
☑️✅Cross-referenced with the relevant national business registry. Optional for US if EIN is provided.
Entity Type
company.entityType
✅✅Determines downstream document and ownership disclosure requirements. See the API reference for the list of supported entity types.
Incorporation Date
company.incorporationDate
✅✅Entities incorporated <2 years ago may trigger additional scrutiny (business plan, SoW, supporting invoices).
Industry
businessProfile.naicsCode
✅✅Accepts a NAICS code, NACE code, or Industry API UUID. Determines whether vertical-specific requirements apply. Refer to available Industry reference codes.
Tax ID
company.taxIdentification.number
✅✅Mandatory for US entities (EIN). Verified against IRS records.
Tax Residence Country
company.taxIdentification.taxResidenceCountryCode
✅✅Establishes tax nexus and triggers jurisdiction-specific associate requirements.

Registered address​

FieldUSEUValidation / why we collect it
Street Address
address.addressLine1
✅✅Verified against business registry.
City
address.city
✅✅Part of full address verification.
Post / Zip Code
address.postalCode
✅✅Part of full address verification.
State / Province
address.stateCode
✅❌Required for US addresses.
Country
address.countryCode
✅✅Decline if in a controlled or prohibited jurisdiction. To get the list of countries, use the Fetch Country Codes endpoint.
Operational Address
company.operationalAddress
☑️☑️Required if different from registered address.

Business profile​

The businessProfile object captures business context, CDD data, and nature-of-business information at customer creation.

FieldUSEUValidation / why we collect it
Description
businessProfile.description
✅✅Brief narrative of business activities. Used by Compliance to assess consistency with declared industry.
Website
businessProfile.website
✅✅Reviewed for risk indicators, consistency with declared activity, and exposure to prohibited content.
Regulated Status
businessProfile.isRegulated
✅✅Triggers requirement for AML Policy and Proof of Regulatory License if true. When true, regulator information fields become mandatory (see below).
Source of Funds
businessProfile.sourceOfFunds
✅✅Structured enum. Documentary evidence may be requested during compliance review. See the API reference for the list of supported values.
Intended Use of Account
businessProfile.intendedUseOfAccount
✅✅Screened for high-risk purposes (e.g. third-party money transmission). Must align with declared business model. See the API reference for the list of supported values.
Monthly Expected Volume
businessProfile.monthlyExpectedVolumes
✅✅Volume range provided as a string enum (e.g. FROM_0_TO_10K). See the API reference for supported values. A UUID-based reference via the Volumes API (company.monthlyExpectedVolumesReference) will replace this field in a future release.
Nature of Business Questionnaire

Previously required for business customers in v1. Deprecated in v2. All business context is now captured via the structured businessProfile fields above.

Regulator information (conditional)​

When businessProfile.isRegulated is true, the following fields become mandatory:

FieldRequiredDescription
Regulator Name
businessProfile.regulatorInformation.regulatorName
✅Name of the regulatory body (for example, "FCA", "FinCEN").
Regulator Jurisdiction
businessProfile.regulatorInformation.regulatorJurisdiction
✅Jurisdiction in which the entity holds its licence. ISO country code or region.
Register Number
businessProfile.regulatorInformation.regulatorRegisterNumber
✅Registration or licence number issued by the regulator.
Partner-Managed

For Partner-Managed integrations, these fields are subject to bilateral agreement.

Associates​

Associates are individuals linked to the business.

Business customers must include associated natural persons. The following minimum roles must be declared:

  • One Authorised Signatory
  • One Director (EU) or Control Person (US)
  • All UBOs above the applicable threshold (25% for onboarding and CDD, 10% for EDD)

Associate roles​

The following values are accepted in the associate roles field. Each associate must be assigned at least one role.

RoleRequirementValidation / why we collect it
Authorised Signatory
SIGNATORY
✅
At least one
Person legally authorised to bind the company and execute agreements. If not a director, evidence of signing authority is required (Board Resolution, PoA, or Articles provision). Previously documented as REPRESENTATIVE.
Director
DIRECTOR
✅
At least one (EU)
EU: verified against the company registry. Sanctions, PEP, and adverse media screening applied.
Control Person
CONTROL_PERSON
☑️
US only
Person with significant management responsibility. Distinct from Director. Accepted by the API as a separate title value.
UBO / Beneficial Owner
BUSINESS_OWNER
✅
All above threshold
CDD threshold: ≥25%. EDD threshold: ≥10%. If no individual above threshold, the most senior executive must be designated as Person with Significant Control. Input value is BUSINESS_OWNER; status responses return UBO.
Account Representative
ACCOUNT_REPRESENTATIVE
❌Operational point of contact for the partnership.

The same person can hold multiple roles, for example, Authorised Signatory + UBO + Director.

Personal information (all associates)​

FieldUSEUValidation / why we collect it
First Name
firstName
✅✅Must match government-issued ID exactly. Used for sanctions and adverse media screening.
Last Name
lastName
✅✅Must match government-issued ID exactly.
Date of Birth
dateOfBirth
✅✅Used for identity matching and screening disambiguation.
Position / Title
person.position
✅✅Role or title at the company (for example, "CEO", "Director", "Managing Member"). Used for sanctions screening context and control-person determination.
Nationality
nationality
☑️✅US: required for Control Persons. EU: all nationalities including dual must be declared. Screened against prohibited nationality lists.
Country of Birth
birthCountryCode
☑️✅US: required for Control Persons. Used for sanctions screening.
Country of Residence
address.countryCode
✅✅To get the list of countries, use the Fetch Country Codes endpoint.
Email Address
emailAddress
✅✅Primary communication channel for verification flows.
Residential Address
address
✅✅Full address required. Must be a physical residential address.
State / Province
address.stateCode
☑️❌Required for US addresses.
Ownership Percentage
ownership.percentage
☑️☑️Required when associate holds UBO title. Numeric (0–100).
Ownership Type
ownership.type
☑️☑️DIRECT or INDIRECT. Required when ownership percentage is provided. Determines whether full chain documentation is needed.

Tax identification (all associates)​

FieldUSEUValidation / why we collect it
Tax ID Number
taxIdentification.number
✅✅SSN mandatory for US persons, verified against database. EU: national tax ID.
Tax ID Country
taxIdentification.taxResidenceCountryCode
✅✅Establishes tax residency.

Identity verification (associates)​

Under the BVNK-Managed model, raw documents are uploaded for BVNK to check via verification partners.

CheckUSEUValidation / why we collect it
ID Document Upload✅✅Front/back image of passport, national ID card, driver's license, or residence permit. Verified items: authenticity, data extraction, expiry, and name/DOB matching.
Selfie / Liveness Upload✅✅Biometric selfie matched against ID document photo. Liveness detection prevents spoofing.
Address Document Upload✅✅Utility bill, bank statement, or government correspondence dated within 3 months. Address must match declared residential address.

Individual CDD​

When associates are onboarded as standalone individual customers (not in a business context), additional CDD fields apply.

FieldUSEUValidation / why we collect it
Employment Status
cdd.employmentStatus
✅✅Used to assess plausibility of declared source of funds. See the API reference for the list of supported values.
Source of Funds
cdd.sourceOfFunds
✅✅High-risk sources trigger SoF documentary request. See the API reference for the list of supported values.
Intended Use of Account
cdd.intendedUseOfAccount
✅✅Screened for high-risk use cases. See the API reference for the list of supported values.
Expected Monthly Volume
cdd.expectedMonthlyVolume
❌☑️ QuestionnaireEU BVNK-Managed: covered in questionnaire or defaults.
PEP Status
cdd.pepStatus
☑️ Questionnaire☑️ QuestionnaireCollected via questionnaire. Positive PEP triggers EDD.

UBO-specific requirements​

UBOs above the ownership threshold must complete identity verification.

CheckUSEUValidation / why we collect it
Basic data + residential address❌ (address)✅EU always requires full residential address. Sanctions, PEP, and adverse media screening applied.
ID Verification✅✅US: SSN mandatory for US residents, verified against database. EU: full ID verification (document or metadata under Partner-managed).
Ownership threshold25% (std) / 10% (high)25% (std) / 10% (high)Standard CDD: ≥25% ownership or voting rights. EDD (high-risk): ≥10%. Full ownership chain required if held through intermediaries.

Business documents (KYB)​

Documents are uploaded via POST /onboarding/v1/applications/{id}/documents (company) or via Portal.

Entity documents​

DocumentUSEUWhy we collect it
Certificate of Incorporation✅✅Confirms legal formation. Must show filing stamp or registration date. Legal name must match declared name.
Memorandum of Association✅✅Confirms governance structure, powers, and objects of the entity.
Articles of Association✅✅Confirms internal governance and signatory authority. Submitted as a separate document type; may be combined with Memorandum where jurisdictionally equivalent.
Source of Funds (Entity)☑️✅Bank statements (3 months activity) or equivalent. US: required only when EDD applies.
Proof of Address (Entity)☑️✅Utility bill, lease, tax statement, or official government correspondence. Dated within 3 months. US: required only for high-risk / EDD.
Proof of Directorship☑️✅Official registry extract or certified register of directors. Not older than 6 months. US: required only for high-risk / EDD.
Corporate / Group Structure✅✅Ownership chart showing all corporate shareholders through to UBOs. Certified by legal counsel or CA. Not older than 6 months.
Source of Wealth (Entity)☑️☑️Triggered by high-risk rating or EDD. Audited accounts, financial statements, loan agreements, or bank statements showing capitalisation history.
Proof of Regulatory License☑️☑️Required if entity operates in a regulated industry. Must be current and match declared jurisdiction.
Proof of Business Activity☑️☑️Triggered when web presence is limited, entity is newly incorporated (<2 years), or nature of business is unclear. Specifically required for EU EDD.
Shareholder Ownership Doc☑️☑️Required when ownership is complex (trusts, foundations, nominees, >3 layers, offshore entities).

Enhanced due diligence​

Enhanced due diligence (EDD) requirements apply when the BVNK customer risk rating is HIGH and EDD has not been completed by the Embedded Partner (reliance.attestation.eddCompleted: false).

Company EDD​

RequirementUSEUWhat we accept
Company Source of Wealth✅✅Loan agreements, financial statements, tax returns, bank statements, or commercial database verification (e.g. Creditsafe).
Source of Funds (Entity)✅✅Document required when EDD applies (replaces the CDD attestation sufficient for standard risk).
Director & UBO Address Verification❌✅Commercial database check or documentary evidence (utility bill, bank statement).
UBO Source of Wealth❌✅Tax returns, investment portfolio statements, share certificates, or open-source research.
Verification of Professional Activity❌✅Payslips, employment contracts, invoices (if self-employed), or open-source review.
Proof of Entity Address✅❌Bank statement or other documentary evidence showing the entity's physical address.

Review process​

Application review​

BVNK reviews applications once all required data, documents, and associate verification have been submitted. Onboarding completes automatically when all conditions are satisfied — there is no separate “submit” call. See the Create business customers guide for completion mechanics.

Decisioning​

Applications result in one of three outcomes: VERIFIED, REJECTED, or remain in SUBMITTED state pending additional information. BVNK sends webhook notifications at each status transition.

Requests for information (RFI)​

When BVNK requires additional information, a consolidated RFI is issued. To minimise RFIs:

  • Submit all formation, ownership, and address documents upfront.
  • Clearly substantiate the nature of business, especially where web presence is limited.
  • For regulated entities, include AML policy and license documentation with the initial submission.
  • Pre-screen business physical addresses for virtual or registered agent addresses.

Best practices​

  • Pre-screen addresses. Confirm the physical address is not a virtual office or registered agent. Wyoming and Delaware addresses in particular require scrutiny.
  • Collect ownership attestation early. Have the control person certify UBOs above the threshold to avoid follow-up document requests.
  • Document the nature of business. Ensure the website or supporting documents substantiate what the business does. For new businesses, provide a business plan or pitch deck.
  • Source of funds upfront. Proactively submit bank statements showing 3 months of transactional activity for BVNK-Managed; provide attestation for Partner-managed CDD.
  • Web presence. If the business has limited or no web presence, attach invoices, contracts, marketing materials, or bank statements as supplementary evidence.
  • Use structured businessProfile fields. The Nature of Business Questionnaire is deprecated in v2 — all business context is captured via structured fields.

Appendix​

Non-MTL US States​

Additional mandatory requirements apply to business customers whose operational address (or registered address, where no operational address is declared) falls in a US state not covered by BVNK's Money Transmitter License (MTL), and where crypto capability for customers has been enabled on the account.

The non-MTL states are not listed in What licenses registrations does BVNK and BVNK's Partners have.

Associates​

The following field is mandatory for all associates linked to the business, including Authorised Signatories, Control Persons, and UBOs:

FieldAllowed values
company.associates.person.estimatedYearlyIncomeINCOME_0_TO_50K, INCOME_50K_TO_100K, INCOME_100K_TO_250K, INCOME_250K_TO_500K, INCOME_500K_TO_750K, INCOME_750K_TO_1M, INCOME_ABOVE_1M

Entity​

The following fields are mandatory at the entity level when businessProfile.isRegulated is true:

FieldNotes
businessProfile.regulatorInformation.regulatorNameName of the regulatory body. Must be explicitly collected and submitted.
businessProfile.regulatorInformation.regulatorJurisdictionJurisdiction in which the entity holds its licence. Must be explicitly collected and submitted.
businessProfile.regulatorInformation.regulatorRegisterNumberRegistration or licence number issued by the regulator. Must be explicitly collected and submitted.
Partner-Managed

The above requirements are subject to bilateral agreement. Contact your BVNK integration manager to confirm which fields apply to your programme.

BVNK's onboarding orchestration surfaces these fields at the point of customer creation where applicable. You do not need to determine eligibility in your integration.

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