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Document submission technical requirement

July 18th, 2023

Release date

  • Jul 31st, 2023

Release type

  • Informational – Sharing technical validations
  • Actionable – If the platform uses non-documentary validation and has existing participants without required documents uploaded

Enhanced validation

Technical validation will be deployed such that any participant who has been verified using documentary verification must have a document uploaded to move to an approved status. See Summary below for additional details on the technical verification.

Please note that the technical logic now aligns with the existing Zero Hash compliance requirement. The compliance requirement is that when a customer is submitted to POST /participants/customers/new with an ID type that is not SSN, the underlying identification document must be uploaded via POST /participants/documents.

Existing participants

Any existing participants validated through documentary verification without the necessary document uploaded will automatically move to submitted status until such document is uploaded. When a document is uploaded for such an existing participant via POST /participants/documents, the participant can move to approved status.

If a Platform has impacted participants, Platform Solutions will send a list of affected participants to such Platform.

Summary

For customer verification, Zero Hash allows:

  • Documentary customer verification: ID types here – Required for non-US permanent residents (i.e., anyone who does not have an SSN). Also permitted for existing US customers who have already provided an identification number from a permissible official identification document, such as a passport or state driver’s license.
  • Non-documentary customer verification: SSN verification – Required for all US residents (with an SSN). Note: Platforms may still submit documentary evidence on top of SSN for these participants if they so choose.

Zero Hash has enhanced the technical logic and error handling around posting participants that have been verified using documentary verification. The technical logic now aligns with the existing Zero Hash compliance requirement that when a customer is submitted to POST /participants/customers/new with an ID type that is not SSN, the underlying identification document must be uploaded via POST /participants/documents.

Note that for US persons, non-documentary validation through SSN is permissible and no document is required to be uploaded.

Until a document is uploaded, the participant remains in a submitted state and is unable to make any requests (i.e., buy, sell, deposit, withdraw) until documents are posted. This logic upholds onboarding requirements for platforms and ensures participants missing necessary verification information are not advanced to approved.

Action required

It is an existing requirement that Platforms must ensure they are posting copies of a participant’s customer ID document that matches the identification (ID) number that was provided via POST /participants/customer/new. No document is required for non-documentary validation, currently only an SSN for US persons. Please note that the ID must be a permitted type.

Once Zero Hash receives the required documents, the participant will move to an approved state. More details on participant statuses here.

Endpoints impacted

If POST /participants/customers/new uses one of the following id_number_type, then an accompanying document is required to be submitted to POST /participants/documents:

  • us_drivers_license
  • us_passport
  • us_passport_card
  • us_permanent_resident_card
  • us_border_crossing_card
  • us_alien_card
  • us_id_card
  • non_us_passport
  • non_us_other

The only exception is SSN (considered non-documentary evidence). For id_number_type “ssn”, or if a U.S. tax_id (i.e., SSN) is submitted, there is no requirement to post a document.

Relevant documentation

API documentation regarding POST /participants/customers/new and POST /participants/documents

Related reminder (updated July 25, 2023)

Platforms also are reminded that as of September 5, 2023 (updated date), Zero Hash is implementing the enhanced “know your customer” or KYC format for all newly submitted retail Participant customers. This change was announced to Platforms on April 26, 2023.

As of September 5, 2023 (updated date), any new newly submitted participants whose application does not meet these standards will be declined.