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Business representatives

Business representatives are individuals with significant control or beneficial ownership of a business entity. Moov must verify these individuals before enabling payment capabilities.

Quick start

  1. Create at least one control officer using the representatives POST endpoint with isController: true
  2. Create all beneficial owners (individuals with ≥25% ownership) with isOwner: true and ownershipPercentage
  3. Confirm ownership by setting ownersProvided: true on the account using the PATCH endpoint
Step 3 is required even if no one owns ≥25% of the business. The Moov Dashboard handles this flow automatically.

Why this is required

Under FinCEN's Customer Due Diligence (CDD) rule, financial institutions must identify and verify the identity of beneficial owners who own 25% or more of a legal entity, as well as at least one individual with significant management responsibility. This helps prevent money laundering and financial crimes.

Moov collects this information through two categories of business representatives:

Type Description Required
Controller An individual with significant management responsibility (CEO, CFO, COO, President, etc.) At least one
Owner An individual who owns ≥25% of the business All who qualify

If one person is both a control officer and beneficial owner, set both isController and isOwner to true. Moov allows a maximum of 7 representatives per account.

Control officer

A control officer is someone with significant management responsibilities and the authority to make decisions within the business. Examples include:

  • CEO, COO, CFO, or other C-suite executives
  • President or Vice President
  • Treasurer or Secretary
  • Managing Partner or General Partner

Create a control officer using the representatives POST endpoint with isController: true and include a jobTitle.

Regardless of how many control officers the business has, you only need to create one.

Owner

US state and federally regulated financial institutions are exempt from beneficial ownership requirements.

A beneficial owner is an individual who owns 25% or more of the business. All beneficial owners must be verified by Moov before payment capabilities can be enabled.

Create each beneficial owner using the representatives POST endpoint with:

  • isOwner: true
  • ownershipPercentage (the percentage they own)

If no individual owns ≥25% of the business, you don't need to create any owners, but you still must set ownersProvided: true on the account to confirm that no individuals meet the 25% threshold.

Data requirements

The table below shows what information is required for each representative type.

Required information Control officer Beneficial owner
Legal name ✓ ✓
Personal address ✓ ✓
Email or phone ✓ ✓
Date of birth ✓ ✓
Full SSN ✓ ✓
isController: true ✓
Job title ✓
isOwner: true ✓
ownershipPercentage ✓

The personal address must be a residential address. The following address types cannot be used:

  • PO Box
  • Commercial mailing receiving agency
  • Registered agent address

Verification timing

Most representative verifications complete automatically within seconds. If Moov cannot verify a representative automatically, you may need to upload supporting documents. Common scenarios requiring documents:

  • Name, address, or date of birth could not be matched
  • SSN could not be verified

See troubleshooting verification for document requirements and resolution steps.

Troubleshoot verification

The individual or business representative’s name could not be verified.
Moov requires an unexpired government issued ID that shows the full name. Acceptable documents include an unexpired drivers license or ID card. In certain situations where an ID is not available, a residential lease or mortgage document may suffice. The address provided cannot be a commercial address.
The individual or business representative’s residential address could not be verified.
Moov requires an unexpired government issued ID that shows the residential address. Acceptable documents include an unexpired drivers license or ID card. In certain situations where an ID is not available, a residential lease or mortgage document may suffice. The address provided cannot be a commercial address.
The individual or business representative's date of birth could not be verified.
Moov requires an unexpired government issued ID that shows the date of birth. Acceptable documents include a drivers license, passport, or ID card.
The individual or business representative’s SSN could not be verified.
Moov requires a government issued document that shows the individual’s SSN. Acceptable documents include a SSN or ITIN card, a tax return statement, or a W2.
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