Business requirements

• Embedded model

This article provides a comprehensive summary of the required fields, document types, identity verification requirements, and applicable conditions for onboarding company customers 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 companion API Integration Guide.

Business entity information

BVNK-Managed

Company profile

Field	Parameter name	US	EU	Validation / why we collect it
company.name	Legal Entity Name	✅	✅	Verified against business registry records. Must match formation documents exactly.
company.registrationNumber	Registration Number	☑️	✅	Cross-referenced with the relevant national business registry. Optional for US if EIN is provided.
company.entityType	Entity Type	✅	✅	LLC, CORPORATION, PARTNERSHIP, SOLE_PROPRIETOR, TRUST, etc. Determines downstream document and ownership disclosure requirements. See the Appendix for the list of supported entity types.
company.incorporationDate	Incorporation Date	✅	✅	Format: YYYY-MM-DD. Entities incorporated <2 years ago may trigger additional scrutiny (business plan, SoW, supporting invoices).
company.industryReference	Industry	✅	✅	UUID from Industry API (NAICS supported). Determines whether vertical-specific requirements apply. Refer to available Industry reference codes.
company.taxNumber	Tax ID	✅	☑️	Mandatory for US entities (EIN). Verified against IRS records.
company.taxResidenceCountryCode	Tax Residence Country	✅	❌	Mandatory for US entities. Establishes US tax nexus and triggers US-specific associate requirements.

Registered address

Field	Parameter name	US	EU	Validation / why we collect it
address.addressLine1	Street Address	✅	✅	Verified against business registry.
address.city	City	✅	✅	Part of full address verification.
address.postalCode	Post / Zip Code	✅	✅	Part of full address verification.
address.stateCode	State / Province	✅	❌	Required for US addresses.
address.countryCode	Country	✅	✅	ISO 3166-1 Alpha-2. Decline if in a controlled or prohibited jurisdiction. To get the list of countries, use the Fetch Country Codes endpoint.
company.operationalAddress	Operational Address	⚠️	⚠️	Required if different from registered address.

Business profile

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

Field	Parameter name	US	EU	Validation / why we collect it
businessProfile.description	Description	✅	✅	Brief narrative of business activities. Used by Compliance to assess consistency with declared industry.
businessProfile.website	Website	✅	✅	Reviewed for risk indicators, consistency with declared activity, and exposure to prohibited content.
businessProfile.customerTypes	Customer Types	✅	✅	Individuals, Businesses, or Both. Used in risk profile assessment.
businessProfile.isRegulated	Regulated Status	✅	✅	Boolean. Triggers requirement for AML Policy and Proof of Regulatory License if true.
businessProfile.sourceOfFunds	Source of Funds	✅	✅	Structured enum. Documentary evidence may be requested during compliance review. See the Appendix for the list of supported values.
businessProfile.intendedUseOfAccount	Intended Use of Account	✅	✅	Screened for high-risk purposes (e.g. third-party money transmission). Must align with declared business model. See the Appendix for the list of supported values.
businessProfile.annualIncomingTransactionValue	Annual Incoming Transaction Value	✅	✅	USD equivalent. Establishes baseline for ongoing transaction monitoring.
businessProfile.annualOutgoingTransactionValue	Annual Outgoing Transaction Value	✅	✅	USD equivalent. Establishes baseline for ongoing transaction monitoring.
businessProfile.monthlyExpectedVolumes	Monthly Expected Volume	✅	✅	Volume range provided as a string enum (e.g. FROM_0_TO_10K). See the Appendix for supported values. A UUID-based reference via the Volumes API (company.monthlyExpectedVolumesReference) will replace this field in a future release.
businessProfile.jurisdictionalPortfolioDistribution	Jurisdictional Portfolio Distribution	✅	✅	Array of {country, percentage}. Jurisdictions representing ≥25% of portfolio. Used to detect exposure to high-risk geographies.
businessProfile.prohibitedJurisdictionsExposure	Prohibited Jurisdictions Exposure	✅	✅	Boolean attestation. Triggers EDD review if true. See the list of Prohibited Countries and Regions in Appendinx I.

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.

Partner-Managed

Company profile

Field	Parameter name	US	EU	Validation / why we collect it
company.name	Legal Entity Name	✅	✅	Verified against business registry records. Must match formation documents exactly.
company.registrationNumber	Registration Number	☑️	✅	Cross-referenced with the relevant national business registry. Optional for US if EIN is provided.
company.entityType	Entity Type	✅	✅	LLC, CORPORATION, PARTNERSHIP, SOLE_PROPRIETOR, TRUST, etc. Determines downstream document and ownership disclosure requirements.
company.incorporationDate	Incorporation Date	✅	✅	Format: YYYY-MM-DD. Entities incorporated <2 years ago may trigger additional scrutiny (business plan, SoW, supporting invoices).
company.industryReference	Industry	✅	✅	UUID from Industry API (NAICS supported). Determines whether vertical-specific requirements apply. Refer to available Industry reference codes.
company.taxNumber	Tax ID	✅	☑️	Mandatory for US entities (EIN). Verified against IRS records.
company.taxResidenceCountryCode	Tax Residence Country	✅	❌	Mandatory for US entities. Establishes US tax nexus and triggers US-specific associate requirements.

Entity-level CDD

For Partner-Managed onboarding, additional business context is provided through structured CDD fields rather than the businessProfile object alone.

Field	Parameter name	US (Partner-Managed)	EU (Partner-Managed)	Validation / why we collect it
company.monthlyExpectedVolumesReference	Monthly Expected Volume	✅	✅	UUID from Volumes API. Establishes baseline for transaction monitoring.
cdd.intendedUseOfAccount	Intended Use of Account	✅	✅	Enum (e.g. SUPPLIER_VENDOR_PAYMENTS, PAYROLL). Partner attests intended use. See the Appendix for the list of supported values.
cdd.pepStatus	PEP Status, Entity	✅	✅	Partner attests whether any person in the ownership or control structure is a PEP.

Partner risk attestation

Field	Parameter name	US (Partner-Managed)	EU (Partner-Managed)	Validation / why we collect it
company.reliance.attestation.riskScore	Risk Score	✅	✅	LOW, MEDIUM, or HIGH. Partner's customer-level risk rating. Input to BVNK's independent risk assessment.
company.reliance.attestation.eddCompleted	EDD Completed	✅	✅	Boolean. If false and BVNK rates the customer HIGH, BVNK-side EDD is triggered.

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 / Representative
• One Director (EU) or Control Person (US)
• One UBO 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.

Role	Parameter name	Requirement	Validation / why we collect it
REPRESENTATIVE	Authorised 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).
DIRECTOR	Director / Control Person	✅ At least one	EU: verified against the company registry. US: person with significant management control. Sanctions, PEP, and adverse media screening applied.
BUSINESS_OWNER	UBO / Beneficial Owner	✅ At least one 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.
ACCOUNT_REPRESENTATIVE	Account Representative	Optional	Operational point of contact for the partnership.

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

Personal information (all associates)

Field	Parameter name	US (BVNK-Managed)	US (Partner-Managed)	EU (BVNK-Managed)	EU (Partner-Managed)	Validation / why we collect it
firstName	First Name	✅	✅	✅	✅	Must match government-issued ID exactly. Used for sanctions and adverse media screening.
lastName	Last Name	✅	✅	✅	✅	Must match government-issued ID exactly.
dateOfBirth	Date of Birth	✅	✅	✅	✅	Format: YYYY-MM-DD. Used for identity matching and screening disambiguation.
nationality	Nationality	⚠️	⚠️	✅	✅	US: required for Control Persons. EU: all nationalities including dual must be declared. Screened against prohibited nationality lists.
birthCountryCode	Country of Birth	⚠️	⚠️	✅	✅	US: required for Control Persons. Used for sanctions screening.
address.countryCode	Country of Residence	✅	✅	✅	✅	ISO 3166-1 Alpha-2. To get the list of countries, use the Fetch Country Codes endpoint.
emailAddress	Email Address	✅	✅	✅	✅	Primary communication channel for verification flows.
address	Residential Address	✅	✅	✅	✅	Full address required. Must be a physical residential address.
address.stateCode	State / Province	⚠️	⚠️	❌	❌	Required for US addresses.

Tax identification (all associates)

Field	Parameter name	US (BVNK-Managed)	US (Partner-Managed)	EU (BVNK-Managed)	EU (Partner-Managed)	Validation / why we collect it
taxIdentification.number	Tax ID Number	✅	✅	✅	✅	SSN mandatory for US persons, verified against database. EU: national tax ID.
taxIdentification.country	Tax ID Country	✅	✅	✅	✅	ISO 3166-1 Alpha-2. Establishes tax residency.

US Partner-Managed (SSN)

When SSN is provided under US Partner-Managed, ID metadata fields become optional.

Identity verification (associates)

ID&V requirements differ by onboarding model. Under BVNK-Managed, raw documents are uploaded for BVNK to verify via Sumsub. Under Partner-Managed, verification metadata is passed confirming the partner has performed ID&V.

BVNK-Managed

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

Partner-Managed

Check	US	EU	Validation / why we collect it
ID Metadata (reliance.identityDocumentMetadata)	☑️	✅	Type, number, expiry date, issuing country, IDV timestamp. Confirms the partner has performed document verification. US: optional if SSN has been provided.
Biometric / Liveness Metadata (reliance.biometricLiveness)	❌	✅	Liveness timestamp confirms partner performed biometric check.
Address Verification Metadata (reliance.addressVerification)	✅	✅	Type: DOC (documentary) or NON_DOC (database/electronic). US: confirm residential address is valid and not a PO Box. EU: full address verification required.

Individual CDD

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

Field	Parameter name	US (BVNK-Managed)	US (Partner-Managed)	EU (BVNK-Managed)	EU (Partner-Managed)	Validation / why we collect it
cdd.employmentStatus	Employment Status	✅	✅	✅	✅	SALARIED, SELF_EMPLOYED, UNEMPLOYED, RETIRED. Used to assess plausibility of declared source of funds.
cdd.sourceOfFunds	Source of Funds	✅	✅	✅	✅	SALARY, PENSION, SAVINGS, CRYPTO_TRADING, etc. High-risk sources trigger SoF documentary request. See the Appendix for the list of supported values.
cdd.intendedUseOfAccount	Intended Use of Account	✅	✅	✅	✅	INVESTMENTS, TRANSFERS_OWN_WALLET, etc. Screened for high-risk use cases. See the Appendix for the list of supported values.
cdd.expectedMonthlyVolume	Expected Monthly Volume	❌	❌	⚠️ Questionnaire	✅	EU BVNK-Managed: covered in questionnaire or defaults. EU Partner-Managed: object {amount, currency} mandatory.
cdd.pepStatus	PEP Status	⚠️ Questionnaire	✅	⚠️ Questionnaire	✅	Partner-Managed: partner must attest status (e.g. NOT_PEP). BVNK-Managed: collected via questionnaire. Positive PEP triggers EDD.

Director-specific requirements

Directors are collected and verified against the company registry. Verification depth depends on model and risk level.

Check	US (Partner-Managed)	EU (Partner-Managed)	Validation / why we collect it
Basic data (name, DOB, nationality, residence)	✅	✅	Cross-referenced against the company's registry of directors. Sanctions, PEP, and adverse media screening applied to all directors.
Residential Address	❌	✅	EU: required for high-risk customers under EDD.
ID Verification Metadata	❌	✅	EU: required for high-risk customers under EDD.

UBO-specific requirements

UBOs above the ownership threshold must complete identity verification.

Check	US	EU	Validation / why we collect it
Basic data + residential address	❌ (address)	✅	EU always requires full residential address. Sanctions, PEP, and adverse media screening applied.
ID Verification	✅ (SSN mandatory)	✅	US: SSN mandatory for US residents, verified against database. EU: full ID verification (document or metadata under Partner-Managed).
Ownership threshold	25% (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

Document	US (BVNK-Managed)	US (Partner-Managed)	EU (BVNK-Managed)	EU (Partner-Managed)	Why 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)	✅	⚠️	✅	⚠️	BVNK-Managed: bank statements (3 months activity) or equivalent. Partner-Managed: attestation sufficient for CDD; documentary evidence required for EDD.
Proof of Address (Entity)	✅	❌	✅	✅	Utility bill, lease, tax statement, or official government correspondence. Dated within 3 months. Required if operational address differs from registered.
Proof of Directorship	✅	❌	✅	❌	Official registry extract or certified register of directors. Not older than 6 months.
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.
Shareholder Ownership Doc	⚠️	❌	⚠️	❌	Required when ownership is complex (trusts, foundations, nominees, >3 layers, offshore entities).

Partner-Managed philosophy

Under Partner-Managed, BVNK relies on the partner's KYB programme. The minimum doc set reflects what BVNK still needs for its own records and regulatory obligations (e.g. Certificate of Incorporation for US Partner-Managed under MTL requirements; Proof of Address for EU Partner-Managed under MiCA).

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

Requirement	US	EU	What 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 API Integration Guide (Section 10) 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

Supported document types

Document types used in POST /documents calls. See the API Integration Guide for the upload format.

Type	Description
CERTIFICATE_OF_INCORPORATION	Certificate of incorporation or business formation
MEMORANDUM	Memorandum of Association
ARTICLE_OF_ASSOCIATION	Articles of Association
PROOF_OF_DIRECTORSHIP	Directors' registry or proof of directorship
CORPORATE_STRUCTURE	Corporate/group structure or shareholder registry
PROOF_OF_OPERATIONAL_ADDRESS	Utility bill, lease contract, or equivalent
SOURCE_OF_FUNDS	Bank statements or equivalent SoF evidence
SOURCE_OF_WEALTH	Audited accounts, tax returns, loan agreements
PROOF_OF_REGULATORY_LICENSE	Current regulatory licence
AML_POLICY	AML policy signed by Director/MLRO/Compliance Officer
SHAREHOLDER_OWNERSHIP	Ownership documentation for complex structures
PASSPORT / ID_CARD / DRIVERS / RESIDENCE_PERMIT	Government-issued ID for associates
SELFIE	Biometric selfie/liveness for associate verification
UTILITY_BILL	Proof of residential address for associates

Accepted entity types

• LLC
• CORPORATION
• PARTNERSHIP
• SOLE_PROPRIETOR
• PUBLICLY_LISTED_COMPANY
• TRUST
• PRIVATE_FOUNDATION
• CHARITY
• NON_PROFIT_ORGANIZATION
• PUBLIC_AGENCIES_OR_AUTHORITIES

Parameter values

Business: Source of Funds (businessProfile.sourceOfFunds)

• COMMERCIAL_ACTIVITIES
• SHAREHOLDER_CAPITAL
• VENTURE_CAPITAL
• SALE_OF_ASSETS
• CRYPTO_FUNDRAISING
• CRYPTO_TRADING_REVENUE
• CORPORATE_LOANS
• OTHER

Business: Intended Use of Account (businessProfile.intendedUseOfAccount / cdd.intendedUseOfAccount)

• SUPPLIER_VENDOR_PAYMENTS
• INTERCOMPANY_TRANSFERS
• PAYROLL
• CUSTOMER_PAYMENTS_RECEIVED
• CUSTOMER_PAYOUTS_REFUNDS_SETTLEMENTS
• OPERATING_EXPENSES
• DIVIDEND_PROFIT_DISTRIBUTIONS
• LOAN_REPAYMENT_FINANCIAL_ACTIVITIES

Business: Monthly Expected Volume (businessProfile.monthlyExpectedVolumes)

• FROM_0_TO_10K
• FROM_10K_TO_50K
• FROM_50K_TO_100K
• FROM_100K_TO_1M
• FROM_1M_TO_10M
• ABOVE_10M

Individual: Intended Use of Account (cdd.intendedUseOfAccount)

• TRANSFERS_OWN_WALLET
• TRANSFERS_FAMILY_FRIENDS
• INVESTMENTS
• GOODS_SERVICES
• DONATIONS

Individual: Source of Funds (cdd.sourceOfFunds)

• SALARY
• PENSION
• SAVINGS
• SELF_EMPLOYMENT
• CRYPTO_TRADING
• GAMBLING
• REAL_ESTATE

Individual: Employment Status (cdd.employmentStatus)

• SALARIED
• SELF_EMPLOYED
• UNEMPLOYED
• RETIRED

PEP Status (cdd.pepStatus)

• NOT_PEP
• DOMESTIC_PEP
• FOREIGN_PEP
• CLOSE_ASSOCIATES
• FAMILY_MEMBERS
• STATE_OWNED (entity only)