Detailed Field Requirements (KYB)
| Field | Type | Required | Description |
|---|---|---|---|
| Name | string | Yes | Business name |
| DBA | string | No | Doing Business As (if applicable) |
| Address | object | Yes | address (street, city, state, zip, country) |
| Phone | string | Yes | Phone number (format: "+1XXXXXXXXXX") |
| State of Incorporation | string | Yes | Two-letter state code |
| EIN | string | Yes | Nine-digit Employer Identification Number |
| Entity Type | enum | Yes | LLC, Partnership, PubliclyTradedCorporation, PrivatelyHeldCorporation, NotForProfitOrganization |
| Website | string | No | Valid URL (or attestation of no website) |
| Contact Name | object | Yes | First and last name |
| Contact Email | string | Yes | Valid email address |
| Contact Phone | string | Yes | Phone number (format: "+XXXXXXXXXX") |
| Officer | object | Yes | Full name, DOB, title, SSN (US persons), passport (non-US persons), email, phone, address, occupation, annual income, source of income |
| Beneficial Owners | array | Yes* | 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 Revenue | enum | Yes** | UpTo100k, Between100kAnd500k, Between500kAnd1m, Between1mAnd5m, Over5m |
| Number of Employees | enum | Yes** | Between1And10, Between11And50, Between51And250, Over250 |
| Cash Flow | enum | Yes** | Cyclical, Predictable, Seasonal, Startup |
| Year of Incorporation | string | Yes | Four-digit year |
| Countries of Operation | array | Yes** | Array of two-letter ISO country codes |
| Business Vertical | enum | Yes | Accounting, 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
| Field | Type | Required | Description |
|---|---|---|---|
| Full Name | object | Yes | First and last name |
| Date of Birth | string | Yes | Format: "YYYY-MM-DD" |
| Title | enum | Yes* | CEO, COO, CFO, President, BenefitsAdministrationOfficer, CIO, VP, AVP, Treasurer, Secretary, Controller, Manager, Partner, Member |
| SSN | string | If US person | Nine-digit Social Security Number (US persons only) |
| Passport Number | string | If non-US person | Passport number (non-US persons only) |
| Passport Country | string | If non-US person | Two-letter ISO country code (non-US persons only) |
| string | Yes | Valid email address | |
| Phone | string | Yes | Phone number (format: "+1XXXXXXXXXX") |
| Address | object | Yes | Residential address (street, city, state, zip, country) |
| Occupation | enum | Yes | ArchitectOrEngineer, 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 Income | enum | Yes | UpTo25k, Between25kAnd50k, Between50kAnd100k, Over100k |
| Source of Income | enum | Yes | EmploymentOrPayrollIncome, SelfEmploymentIncome, DisabilityIncome, InterestOrDividendIncome, RetirementIncome, SocialSecurityIncome |
| Percentage of Ownership | integer | Yes** | Percentage of ownership in the business |
| Government-Issued ID | file | Yes** | 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:
| Field | Type | Required | Description |
|---|---|---|---|
| Sole Proprietorship | boolean | Yes | Indicates if the business is a sole proprietorship |
| EIN | string | No | Nine-digit Employer Identification Number (if applicable) |
| DBA | string | No | Doing Business As (if applicable) |
| Annual Revenue | enum | Yes | Same as Annual Revenue for non-US Officer/Owners |
| Number of Employees | enum | Yes | Same as Number of Employees for non-US Officer/Owners |
| Business Vertical | enum | Yes | Same as Business Vertical for all businesses |
| Website | string | No | Valid URL |
Business Type Requirements Matrix
| Field | C-Corp | LLC | Partnership | Sole Proprietor |
|---|---|---|---|---|
| Name | ✔️ | ✔️ | ✔️ | ✔️ |
| DBA | ✔️ | ✔️ | ✔️ | ✔️ |
| Address | ✔️ | ✔️ | ✔️ | ✔️ |
| Phone | ✔️ | ✔️ | ✔️ | ✔️ |
| State of Incorp. | ✔️ | ✔️ | ✔️ | |
| EIN | ✔️ | ✔️ | ✔️ | Optional |
| Entity Type | ✔️ | ✔️ | ✔️ | |
| Website | ✔️ | ✔️ | ✔️ | Optional |
| 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)