KYC Configuration with Program Flips

There are scenarios where a Person is onboarded in one program with a lower due diligence mode, but later, after undergoing additional KYC verification, they may be upgraded to a program with a higher due diligence mode.

Example Use Case

  • A client has two sub-programs, A (with SDD - Simple Due Diligence) and B (with CDD - Compliance Due Diligence).
  • A Person is onboarded into Sub-Program A after passing an OFAC check (as per SDD).
  • Later, after successfully completing an Electronic ID (EID) verification, they may be allowed to move to Sub-Program B.
Changing a Program means moving the Person's wallet from one program to another.

Key Configuration Consideration

Even though Sub-Program A follows SDD by default, it must also allow CDD verification methods to ensure that the Person can be moved to Sub-Program B after successful verification.
Thus, a program should allow additional KYC configurations to accommodate potential KYC upgrades.


KYC Upgrade Request on a Program

A Person in Sub-Program A (verified under SDD) may request an additional KYC check to meet the CDD requirements of Sub-Program B.

Process in the Perform KYC API Call:

  • The request should include the destination program GUID (i.e., the program the Person wants to be upgraded to).
  • The following conditions apply:
    • The destination program GUID and the Person’s current program GUID must belong to the same top program GUID.
    • If no destination program GUID is provided, the KYC verification is performed under the current program’s due diligence mode:
      • If the Person is already verified, the API responds with "Person Already Verified."
      • If the Person is NOT verified, KYC is performed as per their current program’s due diligence mode.
    • If the destination program GUID is provided, the platform retrieves the destination program’s due diligence mode and attempts KYC verification based on the destination program’s due diligence mode.

Sample API Request:

POST /api/v1/persons/b82503a2-7e16-45d1-a7c9-34a223421a7f/kyc HTTP/1.1
Host: devapi.qolopay.com
Content-Type: application/json
Authorization: {{YOUR_BEARER_TOKEN}}
IdempotencyKey: {{YOUR_IDEMPOTENCY_KEY}}
{
  "perform_kyc": true,
  "program_guid": "3fa0d2ea-ffcf-485d-94ed-dbf4f861ad2f" // Destination Program GUID
}


Change Program API Request (With or Without KYC Upgrade)

A Person’s program change request can occur under two conditions:

  1. Person is already KYC upgraded
  2. Person has not yet undergone a KYC upgrade

Rules for Program Change Requests:

  • If the person is already verified at the required KYC level:
    • The system checks the destination program’s due diligence mode.
    • The program change is allowed if:
      • The Person’s verification level matches or exceeds the destination program’s due diligence requirements.
  • If the person is NOT verified at the required level:
    • The platform attempts a KYC upgrade following the process in identified above under KYC Upgrade Request.
    • If the KYC upgrade is successful, the Person’s program is changed.
    • If the KYC upgrade fails, the API returns an error:
      "Person verification failed for the destination program."

Sample API Request:

POST /api/v1/wallets/changeprogram HTTP/1.1
Host: devapi.qolopay.com
Content-Type: application/json
Authorization: {{YOUR_BEARER_TOKEN}}
IdempotencyKey: {{YOUR_IDEMPOTENCY_KEY}}
{
  "wallet_guid": "17eaeda9-c0ab-4ac3-8ef9-27ac9b388a03",
  "destination_program_guid": "fa634271-8fce-45f1-8c20-febf46d0c6a1"
}



Summary

  • KYC upgrades allow People to transition from lower to higher due diligence programs.
  • Programs must allow additional verification configurations to accommodate potential upgrades.
  • A Person’s program change is only allowed if they meet or exceed the required due diligence mode.
  • If a Person is not yet verified for the higher due diligence mode, the platform attempts a KYC upgrade before allowing the program change.

This flexibility ensures seamless customer onboarding and regulatory compliance, while allowing businesses to scale their offerings efficiently.