Ongoing due diligence for personal customers

Ongoing due diligence (further – ODD) refers to the continuous process of monitoring and evaluating a customer’s profile and activities after the initial onboarding. This is crucial to ensure compliance with Anti-Money Laundering (AML) laws, Counter-Terrorism Financing (CTF) regulations, and Know Your Customer (KYC) requirements. Goals of ongoing due diligence are :

1. To mitigate risks: Continuously monitor customer transactions for signs of suspicious activity, fraud, or illegal behavior, ensuring that any potential threats are identified and addressed early.
2. Compliance Assurance: Ensure that we stay in compliance with evolving regulatory frameworks and legal requirements, including AML, KYC, and CTF regulations.
3. Maintain Customer Profile Accuracy: Update customer data and profiles as necessary, based on new information or changes in their business or financial activity, to ensure ongoing risk assessment is based on the most current and accurate information.
4. Implement Enhanced Due Diligence (EDD): For higher-risk customers or transactions, perform more in-depth scrutiny and reporting to ensure compliance with the financial institution’s risk management protocols.
5. Maintain a Trustworthy Relationship: Build and sustain trust with customers and regulators by demonstrating proactive efforts to prevent financial crimes and ensure transparency in financial activities.

By leveraging APIs to manage this ongoing due diligence process, BaaS partners help streamline compliance and risk management activities, providing robust and scalable solutions for their customers.

Prerequisites

To perform ODD, a personal customer should be already onboarded via our onboarding API.

ID status for such customer should be approved. There is no need to re-do IDV if it’s still valid, but if a document is expired, then this will be requested during ODD process as well.

Monitoring

In order to receive information about incoming ODD date, at phase 1 ConnectPay will share a list of customers that ODD time is coming this year.

At phase 2, there will be separate webhook event to subscribe and track.

Data collection

Based on separate risk scores, ConnectPay maintains 3 different timelines for customers:

• Each 1 year for higher risk customers;
• Each 2 years for medium risk customers;
• Each 3 years for low risk customers.

There are cases when ODD can be triggered by risk-related events as well.

Notification about ODD is prepared 60 days until ODD date – to properly prepare communication for customers and start data collection.

Data is collected via new endpoint POST /baas/onboarding/applications/odd/personal

In the table below we provide API header and descriptions:

In a table below we provide parameter descriptions and constraints:

Request sample:

{
  "baasClientId":"6e0ab99b-f0f7-4ca9-b6d9-35670f5e4bf5",
  "person": {
    "isUbo": true,
    "pep": {
      "isPep": true,
      "position": "string"
    },
    "address": {
      "addressLine1": "string",
      "addressLine2": "string",
      "postcode": "string",
      "city": "string",
      "countryCode": "LT"
    },
    "taxIdentification": {
      "taxCountry": {
        "countryCode": "LT",
        "tin": 123123
      },
      "additionalTaxCountries": [
        {
          "countryCode": "LT",
          "tin": 1231232
        }
      ]
    }
  },
  "account": {
    "connectionToLithuania": [
      "WorkOwnRealEstateHaveCompanyInLt"
    ],
    "requestedProducts": [
      "RailsSwift"
    ],
    "purposesOfAccount": [
      "Salary"
    ],
    "purposesOfAccountAdditionalInformation": {
      "businessActivityRegistrationNo": 123123,
      "businessActivityIndustry": "Test Industry"
    },
    "purposesOfAccountOther": "string",
    "sourceOfIncome": "Other",
    "sourceOfIncomeOther": "Alternate source of income",
    "monthlyGrossTurnover": "1001_3000",
    "intendedCountriesToTransactWith": "LT",
    "occupation": "Employee",
    "occupationAdditionalDetails":{
      "company": "UAB Test123",
      "position": "Midle management"
    }
  },
  "merchant": {
    "paymentMethod": [
      "Card"
    ],
    "targets": {
      "countries": [
        "LT"
      ],
      "monthlyGrossTurnover": {
        "amount": 0,
        "currency": "EUR"
      }
    }
  }
}

Response structure is same as with Onboarding application:

json body with http response code 201

{
  "application": {
    "applicationId": "1bafb8d2-cc0e-4b94-9225-ac9d001a7837",
    "status": "APPLICATION_CAPTURED"
  }
}

Note! Same as personal application v2, ODD application will have x-connectpay-requestid as Response header instead of X-Request-ID.

To receive status of ODD application, same GET Application Status API can be used.

To receive webhook notification, also same Events are used – Application Webhooks.

Possible personal application statuses