Know your customer

Verifying identity is a legal requirement for every regulated payment provider. It protects you from someone else opening an account in your name, it prevents the platform being used to move criminal proceeds, and it allows us to release your payment instructions without unnecessary delay.

The obligation arises from the federal customer identification requirements at 31 USC 5311 and following and 31 CFR Chapter X in the United States, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 in the United Kingdom, national transpositions of the European Anti-Money Laundering Directives across the European Union, and equivalent requirements in every other market where we operate.

At registration we collect the minimum set required to establish who you are:

• Full legal name, including any previous name still shown on your evidence.
• Date of birth.
• Residential address, and any recent previous address where the market requires an address history.
• Nationality and country of tax residence.
• A verified email address and mobile number.
• A government-issued identity document accepted in your country of issue.
• A live selfie used only to confirm that the document belongs to you.
• Where the market requires it, a national identifier such as a taxpayer identification number.

We ask for the purpose of the account and the expected pattern of activity so that later monitoring does not stop legitimate payments unnecessarily. Where activity later diverges materially from what you told us, we may ask again.

The document types offered to you depend on your country of issue, because acceptance criteria differ by jurisdiction. The product only ever displays the types accepted for your country. Commonly accepted types include a passport, a national identity card, a photocard driving licence and a residence permit.

A document must be valid and unexpired, unaltered, fully visible with no cropped edges, legible at the resolution captured, and issued by a recognised authority. Where a proof of address is required, we accept a document dated within the last three months that carries your name and the address you gave us — for example a utility statement, a government-issued statement or a tenancy agreement. We do not accept a document you have edited, redacted or reproduced by hand.

Checks combine automated and human review:

• Document authentication — machine-readable zone validation, security feature checks, tamper detection and expiry validation.
• Biometric comparison — the live selfie is compared to the portrait on the document, with a liveness test to prevent the use of a photograph or recording.
• Data validation — the details you entered are compared with the details extracted from the document and, where lawful and available, with independent reference sources.
• Screening — your name is screened against sanctions lists, and against politically exposed person and adverse media data where required by risk.
• Manual review — a trained reviewer examines any case the automated checks cannot settle. A rejection is never issued by an automated process alone where the law gives you a right to human review.

Verification usually completes within minutes. Manual review typically completes within one business day and can take longer where a document requires specialist examination or a third-party source is unavailable.

We apply enhanced measures where the law or our risk assessment requires it. This can include a politically exposed person or a close family member or associate, a connection to a country subject to enhanced scrutiny, an unresolved screening alert, activity that does not match the stated purpose of the account, or a value or velocity outside your established pattern.

Enhanced measures may involve evidence of the source of the funds involved in a specific payment, evidence of the source of your wealth more generally, additional identity evidence, or a short interview. We explain what is required and why, and we ask only for what is proportionate to the concern.

Every case ends in one of five states, shown in the product with a reference identifier:

• Approved — verification is complete. Outbound activity is available, subject to any separate restriction on your account.
• Pending — the case is with a reviewer. You can use the account for incoming activity where that is permitted, but outbound instructions are not released.
• More information required — a specific item is missing or unreadable. We tell you which item and why, and you can resubmit from the verification screen.
• Rejected — we cannot verify you to the standard required. We give a reason code where the law allows us to.
• Held for review — the case is subject to a review we cannot describe. We are prohibited by law from explaining a hold of this kind, and support cannot provide further detail.

Until verification is approved, outbound payments, payouts, peer-to-peer transfers and card issuance are unavailable. This restriction is a legal control and is applied to every customer equally.

You have the right to a human review of a verification decision that materially affects you. Contact support with the reference identifier shown on the decision and ask for a review; a reviewer who did not make the original decision will examine the case.

Under the United Kingdom and European Union data protection regimes you also have rights of access, rectification, restriction and, in defined circumstances, erasure and objection, together with the right not to be subject to a decision based solely on automated processing that produces a legal or similarly significant effect. Requests are handled as described in the Privacy notice.

Where we are legally prohibited from explaining a decision, we will say that a restriction applies rather than give a misleading reason. We will never ask you to send a document to a personal email address or a messaging application, and we will never ask for your password or a one-time code.

Identity evidence and verification results are retained for at least five years after the end of your relationship with us, because financial crime law requires it. Document images are stored by a specialist verification provider under contract, encrypted at rest and in transit, and are never displayed inside the product, returned to the browser or attached to support correspondence.

Access is restricted to trained reviewers with a demonstrated need, and every access is logged in an append-only audit record.