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Step 4: Certifying Beneficial Ownership

The basics

In order for your business verified Customer to be eligible to send funds, the individual creating the business verified Customer account must certify beneficial owner(s). By certifying that all beneficial owner information is correct, the requirements imposed by the United States Federal customer due diligence rule and Dwolla will be successfully fulfilled.

Certification of beneficial owners should be included as part of the Customer account registration and immediately following the creation of the business Verified Customer and the addition of all owners (unless exempt).

How do I know what business structure is required to certify Beneficial Ownership?

If my Customer’s business structure is……are they required to certify beneficial ownership?
Sole proprietorshipsNo (exempt)
Unincorporated associationNo (exempt)
TrustNo (exempt)
CorporationYes
Publicly traded corporationsYes
Non-profitsYes
LLCsYes
Partnerships, LP’s, LLP’sYes

Determining Certification needed

When a business verified Customer needs to be certified, Dwolla will return a link in the API response after retrieving a Customer. If no certification link is returned, the Customer is either already certified, or is exempt from certification.

Link nameDescription
certify-beneficial-ownershipIndicates that certification is required for this Customer

Example response

{
    "_links": {
        "self": {
            "href": "https://api-sandbox.dwolla.com/customers/41432759-6d65-42e5-a6be-400ddd103b78",
            "type": "application/vnd.dwolla.v1.hal+json",
            "resource-type": "customer"
        },
        "certify-beneficial-ownership": {
            "href": "https://api-sandbox.dwolla.com/customers/41432759-6d65-42e5-a6be-400ddd103b78/beneficial-ownership",
            "type": "application/vnd.dwolla.v1.hal+json",
            "resource-type": "beneficial-ownership"
        }
    },
    "id": "41432759-6d65-42e5-a6be-400ddd103b78",
    "firstName": "Account",
    "lastName": "Admin",
    "email": "accountAdmin@email.com",
    "type": "business",
    "status": "document",
    "created": "2018-05-10T19:59:22.643Z",
    "address1": "66 Walnut St",
    "city": "Des Moines",
    "state": "IA",
    "postalCode": "50309",
    "businessName": "Jane Corp",
    "controller": {
        "firstName": "Jim",
        "lastName": "Controller",
        "title": "CEO",
        "address": {
            "address1": "1749 18th st",
            "address2": "apt 12",
            "city": "Des Moines",
            "stateProvinceRegion": "IA",
            "country": "US",
            "postalCode": "50266"
        }
    }
}

Certification Statuses

certification_statusTransaction Restricted?Description
uncertifiedYes - Cannot send fundsNew business verified Customers that are not exempt are initially placed in an uncertified status.
recertifyNo, for up to 30 daysBusiness verified Customers that are certified and change owner information, OR Business verified Customers that Dwolla needs to obtain more information from relating to beneficial owners are placed in this status.
certifiedNoConfirms the certification of beneficial owners.

Certify ownership

To change the certification status of your business verified Customer account, you will want to POST to the beneficial ownership endpoint. By updating the certification status to certified, the Account Admin creating the business verified Customer is indicating that all information is correct. After the Account Admin certifies that the information provided is accurate and the information the Account Admin submitted has been verified through the identity verified process, your business verified Customer is now ready to transact within the Dwolla network.

POST https://api-sandbox.dwolla.com/customers/56502f7a-fa59-4a2f-8579-0f8bc9d7b9cc/beneficial-ownership
Accept: application/vnd.dwolla.v1.hal+json
Content-Type: application/vnd.dwolla.v1.hal+json
Authorization: Bearer pBA9fVDBEyYZCEsLf/wKehyh1RTpzjUj5KzIRfDi0wKTii7DqY

{
  "status": "certified"
}

...

{
    "_links": {
        "self": {
            "href": "https://api-sandbox.dwolla.com/customers/56502f7a-fa59-4a2f-8579-0f8bc9d7b9cc/beneficial-ownership",
            "type": "application/vnd.dwolla.v1.hal+json",
            "resource-type": "beneficial-ownership"
        }
    },
    "status": "certified"
}
# Using DwollaV2 - https://github.com/Dwolla/dwolla-v2-ruby
customer_url = 'https://api-sandbox.dwolla.com/customers/e52006c3-7560-4ff1-99d5-b0f3a6f4f909'
request_body = {
  :status => "certified"
}

app_token.post "#{customer_url}/beneficial-ownership", request_body
var customerUrl = 'https://api-sandbox.dwolla.com/customers/e52006c3-7560-4ff1-99d5-b0f3a6f4f909';
var requestBody = {
  status: 'certified'
};

appToken.post(`${customerUrl}/beneficial-ownership`, requestBody);
# Using dwollav2 - https://github.com/Dwolla/dwolla-v2-python
customer_url = 'https://api-sandbox.dwolla.com/customers/e52006c3-7560-4ff1-99d5-b0f3a6f4f909'
request_body = {
    "status": "certified"
}

app_token.post('%s/beneficial-ownership' % customer_url, request_body)
<?php
$customersApi = new DwollaSwagger\CustomersApi($apiClient);
$customerId = 'https://api-sandbox.dwolla.com/customers/e52006c3-7560-4ff1-99d5-b0f3a6f4f909';
$certifyCustomer = $customersApi->changeOwnershipStatus(['status' => 'certified' ], $customerId);
?>

Certification Text Example

Example for certification is as follows:

 "I,____ (name of Account Admin), hereby certify, to the best of my knowledge, that the information provided above is complete and correct."

Handling recertify status

If you are adding, removing, or updating information of beneficial owners tied to a business verified Customer account, the certification status will change to recertify.

Instances that you will see your certified business verified Customer change to recertify are as follows:

  • Adding a beneficial owner
  • Removing a beneficial owner
  • Updating a beneficial owner in incomplete status
  • Uploading a document to a beneficial owner

When a Customer has a recertify beneficial ownership status, they will have up to thirty days to update and verify their beneficial owners’ information and update their status to certified. If the certification status isn’t updated within this timeframe, the business verified Customer will have its certification_status changed to uncertified, leaving the Customer unable to transact.


Next steps

Review previous steps


Status
Production: Operational

Financial institutions play an important role in the Dwolla network.

Dwolla, Inc. is an agent of Veridian Credit Union and all funds associated with your account in our network are held in one or more pooled accounts at Veridian Credit Union. These funds may not be eligible for share insurance by the National Credit Union Share Insurance Fund. Dwolla, Inc. is the operator of a software platform that communicates user instructions for funds transfers to Veridian Credit Union.