ConnexPay KYB Guidelines
Overview
In order for ConnexPay to meet its regulatory compliance obligations, ConnexPay direct Clients must provide transparency into their authorized users of the ConnexPay services (Customers) and corresponding transaction activity.
ConnexPay’s direct clients are required to conduct appropriate Know Your Business (KYB) and Client Due Diligence (CDD) reviews on all Customers and provide ConnexPay their completed KYB and CDD reviews along with details of all transaction activity.
Know Your Business (KYB) and Client Due Diligence (CDD)
Process
1. ConnexPay Client provides ConnexPay with their KYB/CDD policies and procedures.
2. ConnexPay reviews and confirms the policies are sufficient for ConnexPay and bank sponsors.
3. ConnexPay Client shares the list of Customers with ConnexPay which includes legal entity name, office location, anticipated volume by amount, and nature of card usage (i.e. advertising, inventory, etc.) for each business.
4. ConnexPay approves (or rejects) the list of Customers.
5. Subfolders are created in SharePoint by ConnexPay for each approved Customer.
6. KYB information, including “CDD Criteria” below, is shared by uploading the completed review by the ConnexPay Client of their Customer.
7. Incremental new clients repeat steps 5 and 6.
CDD Criteria
• Evidence of business formation
• Ownership structure
• Passport (or equivalent identification) for any individual with greater than 25% ownership
• OFAC reviews within the last six months of the business and owner
• Tax ID confirmation or equivalent for local jurisdiction
• Business license or equivalent for local jurisdiction
• Bank statement within the last 90 days
• Address confirmation
Data Sharing
The ConnexPay Client must designate one or more employees responsible for sharing documentation to ConnexPay. Access will be granted by ConnexPay only to those specific users to the SharePoint folder.
ConnexPay will provide the SharePoint URL to which the ConnexPay Client will submit documentation. The ConnexPay Client has access to only their folder and subfolders. The subfolders include specific folders for the KYB of each of their customers.
Timelines
The ConnexPay Client must:
• Notify ConnexPay (risk@connexpay.com) of each new Customer prior to any issuing activity.
• Submit documentation of any new Customer at least one month prior to issuing activity with the Customer.
• Respond to any questions or requests ConnexPay may have regarding the Customer subsequent to their onboarding.
Transaction Requirements
ConnexPay Clients must assist ConnexPay in providing visibility into the Customers payments and the supplier to which they are being paid. There are two options outlined below:
1. The ConnexPay Client indicates in the “Customer ID” field of the virtual card as to which business is using the card. The “Supplier ID” field is populated with the supplier’s name when a single supplier is used.
2. The ConnexPay Client provides a weekly report of transactions from their system that identifies purchases for the prior week by business. The report can be submitted to the existing SharePoint site weekly.
Contact
ConnexPay Clients may reach out to their corresponding Sales Representative, Relationship Manager or may contact the ConnexPay Risk Management team at risk@connexpay.com.
