Wingspan KYC/KYB/AML Requirements

Detailed Field Requirements (KYB)

NamestringYesBusiness name
DBAstringNoDoing Business As (if applicable)
AddressobjectYesaddress (street, city, state, zip, country)
PhonestringYesPhone number (format: "+1XXXXXXXXXX")
State of IncorporationstringYesTwo-letter state code
EINstringYesNine-digit Employer Identification Number
Entity TypeenumYesLLC, Partnership, PubliclyTradedCorporation, PrivatelyHeldCorporation, NotForProfitOrganization
WebsitestringNoValid URL (or attestation of no website)
Contact NameobjectYesFirst and last name
Contact EmailstringYesValid email address
Contact PhonestringYesPhone number (format: "+XXXXXXXXXX")
OfficerobjectYesFull name, DOB, title, SSN (US persons), passport (non-US persons), email, phone, address, occupation, annual income, source of income
Beneficial OwnersarrayYes*Full name, DOB, SSN (US persons), passport (non-US persons), email, phone, address, percentage of ownership, occupation, annual income, source of income, government-issued photo ID
Annual RevenueenumYes**UpTo100k, Between100kAnd500k, Between500kAnd1m, Between1mAnd5m, Over5m
Number of EmployeesenumYes**Between1And10, Between11And50, Between51And250, Over250
Cash FlowenumYes**Cyclical, Predictable, Seasonal, Startup
Year of IncorporationstringYesFour-digit year
Countries of OperationarrayYes**Array of two-letter ISO country codes
Business VerticalenumYesAccounting, AdvertisingOrMarketing, AgricultureOrMining, BusinessSupportOrBuildingServices, ConstructionOrEngineering, ConsumerServices, EducationOrTraining, EntertainmentOrGaming, FinanceOrInsurance, FoodAndBeverage, HealthcareOrSocialServices, InformationTechnologyOrComputers, Manufacturing, MediaOrTelecommunications, PersonalServices, RealEstate, RestaurantOrBars, RetailOrWholesaleTrade, TechnologyMediaOrTelecom, TransportationOrLogistics, TravelOrTourism, UtilitiesEnergyOrWaste, Other

*Required if any beneficial owner has >25% ownership
**Required for non-US officers/owners only

KYC for Officers, Beneficial Owners and Sole Props

Full NameobjectYesFirst and last name
Date of BirthstringYesFormat: "YYYY-MM-DD"
TitleenumYes*CEO, COO, CFO, President, BenefitsAdministrationOfficer, CIO, VP, AVP, Treasurer, Secretary, Controller, Manager, Partner, Member
SSNstringIf US personNine-digit Social Security Number (US persons only)
Passport NumberstringIf non-US personPassport number (non-US persons only)
Passport CountrystringIf non-US personTwo-letter ISO country code (non-US persons only)
EmailstringYesValid email address
PhonestringYesPhone number (format: "+1XXXXXXXXXX")
AddressobjectYesResidential address (street, city, state, zip, country)
OccupationenumYesArchitectOrEngineer, BarberOrBeautician, Carpenter, Cashier, ComputerProgrammer, Consultant, DayCareProvider, Doctor, Engineer, FarmOrRanchEmployee, FinancialAdvisor, Janitor, Landscaper, Manager, MassageTherapist, MechanicOrMachinist, Nurse, PersonalAssistant, PersonalTrainerOrInstructor, Plumber, RealEstateAgent, RetailWorker, SalesRep, SkilledTradesWorker, SoftwareDeveloper, SystemsAdministrator, TeacherOrTutor, Writer
Annual IncomeenumYesUpTo25k, Between25kAnd50k, Between50kAnd100k, Over100k
Source of IncomeenumYesEmploymentOrPayrollIncome, SelfEmploymentIncome, DisabilityIncome, InterestOrDividendIncome, RetirementIncome, SocialSecurityIncome
Percentage of OwnershipintegerYes**Percentage of ownership in the business
Government-Issued IDfileYes**Front and back images of a valid, unexpired government-issued photo ID (Driver's License, State ID, or Passport)

*Required for Officer object only
**Required for Beneficial Owners object only

KYC for Sole Proprietorships

When a business is identified as a sole proprietorship, the following additional fields become required:

Sole ProprietorshipbooleanYesIndicates if the business is a sole proprietorship
EINstringNoNine-digit Employer Identification Number (if applicable)
DBAstringNoDoing Business As (if applicable)
Annual RevenueenumYesSame as Annual Revenue for non-US Officer/Owners
Number of EmployeesenumYesSame as Number of Employees for non-US Officer/Owners
Business VerticalenumYesSame as Business Vertical for all businesses
WebsitestringNoValid URL

Business Type Requirements Matrix

FieldC-CorpLLCPartnershipSole Proprietor
State of Incorp.✔️✔️✔️
Entity Type✔️✔️✔️
Contact Info✔️✔️✔️✔️
Officer Info✔️✔️✔️
Beneficial Owners✔️✔️✔️
Annual Revenue✔️*✔️*✔️*✔️
Number of Employees✔️*✔️*✔️*✔️
Cash Flow✔️*✔️*✔️*
Year of Incorp.✔️✔️✔️
Countries of Oper.✔️*✔️*✔️*
Business Vertical✔️✔️✔️✔️

*Required only for non-US officers/owners

Wingspan's Risk-Based Approach

  • Each application is assessed for risk based on factors such as business type, industry, geography, and ownership structure
  • The risk level (Low, Medium, High) determines the level of due diligence required:
    • Low Risk: Simplified Due Diligence (SDD)
    • Medium Risk: Standard Due Diligence
    • High Risk: Enhanced Due Diligence (EDD)
  • High-risk factors include: non-US officers/owners, high-risk industries, high-risk geographies, complex ownership structures, PEPs, adverse media hits

Customer Identification Program (CIP)

  • Wingspan verifies the identity of all beneficial owners and control persons
  • Identity verification methods include:
    • Documentary (e.g., government-issued ID, proof of address)
    • Non-documentary (e.g., public records, credit reports)
  • Additional verification is required for non-US persons (passport information and country of issuance)
  • Government-issued photo ID is required for all beneficial owners

Watchlist Screening

  • All customers (businesses and individuals) are screened against the following watchlists:
    • OFAC Sanctions Lists (SDN, FSE, SSI, UN, NS-ISA, FSE, EO13599, CAPTA)
    • Politically Exposed Persons (PEPs) lists
    • Adverse media databases
  • Potential matches are reviewed by the compliance team to determine if they are true matches or false positives
  • True matches result in the customer being declined or, if already onboarded, having their account frozen and reported to the appropriate regulatory authorities
  • High-risk matches that are not definitively confirmed undergo enhanced due diligence before a final decision is made

Enhanced Due Diligence (EDD)

  • High-risk customers, as determined by the risk assessment, undergo EDD
  • Additional information collected for EDD may include:
    • Detailed source of funds and wealth
    • Expected account activity and transaction volumes
    • Business formation documents and operating agreements
    • Site visits or in-person interviews
  • High-risk customers are subject to more frequent ongoing monitoring (at least quarterly)