Effective November 1, 2018, Partners who submit applications through the REST API will be required to comply with FinCEN and make additional changes to the REST API to support these requirements. As mentioned in previous communications, there are required fields for applications sent via REST API, as well as in the online application link. Partners will receive an error if these fields are not included and the application will not be successfully submitted. If you have questions about this feel free to contact your Account Manager.
- Owner title will be made a required field. Please note that the title is not required for owner_2, owner_3, owner_4.
- If the owner or owner_x object is submitted, all of these fields are required (except where noted):
- Percentage [omit for government, publicly held corporation, sole proprietorship]
- First name
- Last name
- Street address
- Locality
- Region
- Postal code
- Country (optional for government, sole proprietorship, publicly held corporation)
- Citizenship (optional for government, sole proprietorship, publicly held corporation)
- Email address
- Mobile phone
- Last 4 digits of the social security number
- Date of birth
- Percentage details:
- Owner percentage must be between 0 and 100 (inclusive)
- Owner_x percentage must be between 25 and 100 (inclusive)
- Owner_1 percentage + owner_2 percentage + owner_3 percentage + owner_4 percentage <= 100
- Each owner can only be specified at most once. NOTE: If the controller is also an owner, they should be specified only once in the owner object.
- For government, publicly held corporation or sole proprietorship, there can be only one owner object; owner_2, owner_3 and owner_4 must not be submitted.
- Ownership percentage for government and the publicly held corporation must be 0 or not provided.
- Ownership percentage for sole proprietorship must be 100 or not provided.
- The owners have to be submitted in order; e.g., owner and owner_4 cannot be submitted, without owner_2 and owner_3.