CIP and KYC Certification

Federal regulations require collection and verification of specific identity information from merchants. These regulations are designed to prevent the misuse of financial systems and prevent financial crimes such as money laundering and terrorist financing. This document describes the information merchants are required to provide in order to use financial systems. All merchants must meet these requirements before they can complete payment processing and settle funds with WePay.


Merchant Information

 

The following information must be collected from each merchant:

1. Merchant’s Entity Type

The charts below show different entity types and descriptions. Your platform must provide this full list to enable each merchant in declaring their entity type.

Entity Type Description
Individual Merchant wants to collect money for personal reasons.
Sole Proprietor Merchant is the sole owner of an unincorporated business.
Merchant may have an EIN (US) or Business Number (Canada).
Corporation Business is registered with the government or formed under a partnership agreement.
Business has an EIN (US) or Business Number (Canada).
Business is incorporated.
LLC Business is registered with the government or formed under a partnership agreement.
Business has an EIN (US) or Business Number (Canada).
Business is registered with the government as a Limited Liability Company.
Partnership Business is registered with the government or formed under a partnership agreement.
Business has an EIN (US) or Business Number (Canada).
Business is formed under a partnership agreement.
Nonprofit Corporation Nonprofit has an EIN (US) or Business Number (Canada).
Nonprofit is incorporated.
Unincorporated Association Nonprofit has an EIN (US) or Business Number (Canada).
Nonprofit is not incorporated.
Personal Trust/Estate Merchant is a settlor, trustee, beneficiary, or controller of a trust agreement.
The beneficiaries of the trust are individuals.
Statutory Trust Merchant is a settlor, trustee, beneficiary, or controller of a trust agreement.
Trust was created or authorized by legal statute.
Government Agency Merchant is acting on behalf of a government agency.

3. Government Identification Number

The charts below summarize the required government identification numbers that need to be provided.

Entity Type Required identification number
Individual US: Social Security Number (SSN)1
CAN: Social insurance number
Sole Proprietor US: SSN or Employer Identification Number (EIN), if available
CAN: Social insurance number or Business Number, if available
Corporation
LLC
Partnership
Nonprofit Corporation
Unincorporated Association
Personal Trust/Estate
Statutory Trust
US: EIN
CAN: Business Number
Government Agency N/A

1 WePay generally requests the last four digits of SSN (SSN4) to verify an individual’s SSN, but will require full SSN (SSN9) if unable to verify a merchant with the provided SSN4.

4. Merchant’s Full Address

5. Description of Merchant

6. Merchant website (if available)

7. Merchant phone number

A merchant that is a legal entity (i.e. not an individual or sole proprietor) has a controller. A controller is a single individual with significant responsibility to control, manage, or direct a legal entity customer such as an executive officer, senior manager or other individual who regularly performs similar control functions.

The following information must be collected from a controller:

  1. Full Name
  2. Job title: Some examples of different titles for a controller are: Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer.
  3. Full Residential Address
  4. Phone number
  5. Date of birth (month, day, year)
  6. SSN (US only)

For merchants that are legal entities, a beneficial owner is someone who owns 25% or more of the merchant’s equity. Since nonprofit organizations do not have owners or equity, there are no beneficial owners for nonprofits.

The following information must be collected from a beneficial owner:

  1. Full Name
  2. Full Residential Address
  3. Phone number
  4. Date of birth (month, day, year)
  5. SSN (US only)

Attestation

 

In addition to simply collecting the elements described above, federal regulations require that the person certify to the completeness and accuracy of the information provided. Traditionally, this requirement is fulfilled by including a specific attestation language and obtaining signature on the same form used to collect identity information.

Note: This attestation should be included not only when the identity information is submitted for the first time, but also when identity information is updated.

In a digital setting, this requirement can be fulfilled by including attestation language in the same user experience used to collect identity information and obtaining the electronic equivalent of a signature - timestamp, IP address, username (or any other ID). Sample attestation language is provided here:

“By clicking “Submit,” you hereby certify, to the best of your knowledge, that the information provided above is complete and correct.”

As an example, WePay provides this language in the embedded and hosted KYC flow:

Attestation Example


Certification Checklist

In summary, you must provide, and will only be certified after you provide:

  1. UIs providing the complete list of entity types for your merchants to select from
  2. UIs for collecting the correct identification numbers (e.g., EIN or Business Number) from each merchant based on entity type and country
  3. UIs for all required merchant information fields
  4. UIs for all required controller information fields for all entity types except individuals and sole proprietors
  5. UIs for all required beneficial owner fields for all entity types except individuals, sole proprietors, and nonprofits
  6. UIs to collect attestation from the merchant