How it works for your payment institution
Your app opens a case file for the new customer through the REST API, adds the person and starts a procedure. Your customer logs in to the client portal with a code by email and does their part there. Anyone who stops halfway picks up where they left off, and a reminder helps them along.
A private customer verifies with an identity document and selfie and then signs the framework contract. A business customer gets a procedure of its own, with for example a UBO declaration and a registry extract or articles in document management. You draft the framework contract in the contract builder, and your customer signs exactly the version they were shown. Templates for forms and contracts are ready to use, and the portal carries your branding.
Once your customer is done, the procedure.completed webhook tells your app, and your app starts the screening for PEP status, sanctions, adverse media and country. That way you only screen people who finish signing up. A company is also screened on industry. Your team adds a business customer’s directors and shareholders to the structure tree, and RiskResolve completes a Dutch legal entity from the trade register.
Once screening is done, a signed webhook goes to your app, and your app fetches the result. Your analyst compares a matched PEP or sanctions profile with the customer and marks it relevant, false positive or action required, so only a real hit counts. With workflows a customer with a hit takes a different route by itself.
A reviewer approves the case file in the app. The dossier.approved webhook then reports the decision, and only then does your app activate the customer. After that the customer is re-screened by itself, more often as the risk rises.
Dutch payment institutions fall under the Wwft
Payment institutions, e-money institutions and payment service agents fall under the Wwft, through Article 1a(3), points (b), (e) and (j). DNB supervises them (Article 1d(1)(a)) and sets out its expectations in the DNB Q&As and Good Practices on the Wwft of 8 May 2024.
Under Article 3(2) Wwft, a payment institution’s client due diligence covers, among other things, identifying and verifying the customer, establishing the ultimate beneficial owner (UBO), the purpose and nature of the relationship, and ongoing monitoring. It is required when a business relationship starts and at the other moments listed in Article 3(5).
Payment and e-money institutions can apply to the Dutch Chamber of Commerce for their own access to the UBO register. In RiskResolve your team records a business customer’s directors, shareholders and UBOs in the structure tree. From a calculated 25 percent stake, the tree marks a person as a possible UBO.
RiskResolve records sign-up and client due diligence per customer. Transaction monitoring, threshold checks and reports to FIU-the Netherlands run in your institution’s own systems.
Questions from payment firms on KYC
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