Person Management and KYC

Overview

A Person on the Qolo platform is a fundamental entity that represents an individual or a business entity. Every account holder, cardholder, client, program partner, and third-party service provider is categorized as a Person within the system.

The Person entity stores essential identity and financial information, enabling seamless interactions across the platform. The Person record is a prerequisite for creating wallets, accounts, cards, and transactions within a Program.


Types of Persons

Depending on the use case, a Person can represent various roles, including but not limited to:

  • Accountholders – Individuals or businesses holding a Qolo account.
  • Cardholders – Individuals issued with a payment card linked to a Qolo account.
  • Related Persons – Individuals associated with an accountholder or business, such as authorized users.
  • Beneficial Owners – Individuals with ownership or control over a business entity.
  • Money Senders – Individuals initiating fund transfers.
  • Beneficiaries – Recipients of transferred funds.

Person Contact Type

The person_contact_type parameter identifies the type of Person in the Qolo platform. This classification determines the role and applicable attributes of the Person within a program. Some commonly used person_contact_type are:

Types of Person Contact

  1. Accountholder / Cardholder
  • This refers to the individual or business entity that owns and operates a Qolo Account or Card.
  • Can be categorized as:
    • Individual – A natural person who holds a wallet with an account or card.
    • Corporate – A business entity that holds a wallet with an account or card in its name.
  • Example:
    • An individual using a prepaid card for personal expenses.
    • A business entity managing corporate disbursements via a Qolo account.
  1. Program Person
  • This is the Person responsible for managing a Program within the Qolo platform.
  • Typically, a Program Person belongs to the company operating the Program and has administrative privileges.
  • Example:
    • A fintech service provider managing multiple clients under its program.
    • A corporate entity overseeing account funding, compliance, and reporting for its users.

The person_contact_type parameter ensures that the correct attributes, rules, and permissions are applied based on the Person’s role within the program.


Person Attributes

Each Person record contains important details, including:

  • Name – Name of the individual or the business.
  • Identification Information (Date of Birth, SSN, Business EIN, etc.) – Usually required for KYC.
  • Contact Information (Email, Phone Number, Address)
  • KYC (Know Your Customer) Status – Determines whether the Person has passed compliance checks.
  • Person Contact Type – Identifies the type of person as explained above.
  • Wallets & Accounts – A Person may have multiple wallets, each holding one or more accounts and cards.
  • Relationships – Associations with other entities, such as businesses or authorized users.
The Person Attributes that are required or optional depends on the specifications of the Program under which the person is created.
For example:
  • A non-KYC program may not require Person Identification Information and KYC status.
  • An anonymous card program may not require Person Contact Information.

Creating a Person

Before issuing a card or opening an account, a Person record must be created.

Steps to Create a Person

  1. Call the Create Person API with the required details, such as name, date of birth (for individuals), or business information, as required by your Program parameters.
  2. Receive a unique person_guid in response, which serves as the identifier for that Person.
  3. Perform KYC Verification (if required by the program, and not done automatically).
  4. Create Wallet, Accounts and Cards as per the Program business case.

POST /api/v1/persons HTTP/1.1
Host: devapi.qolopay.com
Content-Type: application/json
Authorization: {{YOUR_BEARER_TOKEN}}
IdempotencyKey: {{IDEMPOTENCY_KEY}}
Content-Length: 840

{
    "person_details": {
        "identifications": [
            {
                "govt_id_type": "COUNTRYID",
                "govt_id_number": "112223333"
            }
        ],
        "client_reference_id": "d84efeee-8091-490b-9422-bf078cc7f16c",
        "birth_date": "1975-02-28",
        "email": "[email protected]",
        "first_name": "John",
        "last_name": "Smith",
        "contact_type": "INDIVIDUAL", // Defaults to Individual
        
        "base_address": {
            "address_line1": "222333 PEACHTREE PLACE",
            "address_line2": "",
            "city": "Atlanta",
            "state": "GA",
            "postal_code": "30318",
            "country": "USA"
        }
        
    },
    "program_guid": "AE12FDF2-75BC-451A-839E-EA376D3CA7D2",
    "create_account": true,
    "account_type": "GENERAL",
    "account_currencies": [
        "USD"
    ]
}

Refer to the recipe below for a walkthrough on creating a Person.



KYC Verification for Persons

Certain program require person to pass KYC verification before they can transact. The program configuration requiring KYC is driven by the KYC Verification Modes.

KYC Verification Modes

KYC verification modes define the methods and processes used for verifying a Person during onboarding. These modes are configured at the Program level and determine the extent of due diligence performed by Qolo.

Qolo supports four verification modes:

  1. NDD (No Due Diligence)
  • Qolo does not conduct any due diligence on the person.
  • Suitable for anonymous programs or programs where the client handles all due diligence independently.
  • Default Pass KYC Level: KYC_NA.
Example Use Case: A gift card program where user identity verification is not required.

  1. SDD (Simple Due Diligence)
  • Qolo performs a basic OFAC / negative list check on the person.
  • Ideal for corporate-funded programs or programs where clients conduct the standard KYC checks while Qolo performs minimal screening.
  • Default Pass KYC Level: KYC_PASS_LVL1.
  • Additional Options:
    • Manual document verification can be enabled to clear false positives.
    Example Use Case: A corporate expense management program where employees receive prepaid cards.

  1. CDD (Compliance Due Diligence)
  • Qolo conducts standard KYC checks using Electronic Identity Verification (EID), followed by Out-of-Wallet (OOW) questions and/or document verification, if required.
  • Suitable for consumer programs or when Qolo acts as the Program Manager.
  • Default Pass KYC Level: KYC_PASS_LVL1.
  • Additional Options:
    • Electronic or manual document verification can be enabled to clear false positives.
    Example Use Case: A fintech offering debit cards to individuals, where Qolo acts as Program Manager and performs compliance checks before enabling account for transactions.

  1. EDD (Enhanced Due Diligence) – Reserved for Future Use
  • Qolo performs advanced KYC verification, including:
    • Standard KYC checks (EID, OOW, document verification)
    • Face-ID comparison
    • Risk based assessments
  • Designed for high-risk consumer programs requiring deeper identity verification.
  • Default Pass KYC Level: KYC_PASS_LVL2.
  • Additional Options:
    • Electronic or manual document verification can be enabled for false positive resolution.
    Example Use Case: A consumer funded debit card allowing access to sending and receiving funds from external bank accounts and cards.

Each Program is configured with a specific KYC verification mode based on its risk profile, regulatory requirements, and operational model.