Outsourced: Onboard a society

Under our outsourcing model, Griffin does not perform independent third-party verification of the data you submit. We define the information required to meet account opening and regulatory reporting obligations, and when data is submitted, we validate that the required fields are present and screen the customer against our appetite criteria — including industry, jurisdiction, and risk profile.

To check the different types of entities you can onboard using Outsourced, see Entities we onboard.

Outsourced onboarding is for firms which Griffin has a pre-existing agreement with to outsource the onboarding processes to. If you don't have this agreement in place, this onboarding guide does not apply to you.

caution

Only users with the compliance role can create and submit Outsourced applications.

Process overview

There are four steps to onboarding a society via Outsourced:

Capture the customer information
Create the legal persons
Run the verification
View the verification outcome and onboarding decision

1. Capture the customer information

Society information

Information	Claim	Required
Society name	`entity-name`	✓
Registered address	`entity-address`	✓
Society type	`fca-mutuals-register`	✓
Mutuals register number	`fca-mutuals-register`	✓
Registration act	`fca-mutuals-register`	✓
Business size	`business-size`	✓
SIC codes	`sic-codes`	✓
Tax residencies	`tax-residencies`	✓
External risk rating	`external-risk-rating`	✓
FCA Firm Reference Number	`fca-fs-register-firm`	Required when `society-type` is `credit-union` or `building-society`

The society-type value determines which registration-act applies. Use the table below to find the correct act for the society you are onboarding:

Society type	Registration act
`building-society`	Building Societies Act 1986
`credit-union`	Credit Unions Act 1979 or The Credit Unions (Northern Ireland) Order 1985 or Co-operative and Community Benefit Societies Act (Northern Ireland) 1969
`co-operative-society`	Co-operative and Community Benefit Societies Act 2014 or Co-operative and Community Benefit Societies Act (Northern Ireland) 1969

info

Note: this is the data we require to be sent to our system. A larger set of data requirements will be required from the customer by the outsourcing party (you) to complete CDD and risk rate the customer.

Governing body member and senior manager information

For each individual linked to the society, you'll need:

Information	Claim	Required
Full name (given name)	`individual-identity`	✓
Middle name	`individual-identity`	Optional
Full name (surname)	`individual-identity`	✓
Date of birth	`individual-identity`	✓
Governing body member role	`governing-body-member`	✓ (every linked individual must have this or `senior-manager-function-holder`)
Senior manager role	`senior-manager-function-holder`	✓ (every linked individual must have this or `governing-body-member`)
Role titles	`role-titles`	✓ (required for every linked individual)
FCA Individual Reference Number	`fca-fs-register-individual`	Required when individual holds a `senior-manager-function-holder` role

info

Every individual linked to the society must hold at least one of governing-body-member or senior-manager-function-holder. An individual may hold both.
Every linked individual must have a role-titles claim describing their position(s) at the Society, for example Chief Executive Officer, Secretary, Compliance Officer.
Individuals holding a senior-manager-function-holder role must also provide their FCA Individual Register reference number via the fca-fs-register-individual claim.

2. Create the legal persons

In the API, your customer is represented as a legal person, and each of the data points above represent one claim about them. Create a corporation legal person to represent the society, then add claims about it and any governing body members or senior managers.

Create the society legal person

The example below uses a credit union, which requires a fca-fs-register-firm claim.

curl "https://api.griffin.com/v0/organizations/${ORGANIZATION_ID}/legal-persons" \
  -H "Authorization: GriffinAPIKey $GRIFFIN_API_KEY" \
  -H 'Content-Type: application/json' \
  -d \
'{
  "display-name": "Northside Credit Union",
  "legal-person-type": "corporation",
  "claims": [
    {
      "claim-type": "entity-name",
      "entity-name": "Northside Credit Union"
    },
    {
      "claim-type": "entity-address",
      "address-line-1": "10 Riverside Road",
      "city": "London",
      "postal-code": "EC2V 9AN",
      "country-code": "GB"
    },
    {
      "claim-type": "fca-mutuals-register",
      "fca-mutuals-register-number": "486CU",
      "society-type": "credit-union",
      "registration-act": "credit-unions-act-1979"
    },
    {
      "claim-type": "business-size",
      "business-size": "small"
    },
    {
      "claim-type": "sic-codes",
      "sic-codes": ["64922"]
    },
    {
      "claim-type": "tax-residencies",
      "tax-residencies": ["GB"]
    },
    {
      "claim-type": "external-risk-rating",
      "external-risk-rating": "low-risk"
    },
    {
      "claim-type": "fca-fs-register-firm",
      "fca-firm-reference-number": "123456"
    }
  ]
}'

A successful response will display the URL for the newly created legal person (e.g. /v0/legal-persons/lp.njk7tIWvQJGPEFIdDmS9yQ) in the response's Location header and in the response body. Save this URL for the next step.

Create governing body member and senior manager legal persons

For each governing body member or senior manager, create an individual legal person. Include all their claims in the same request. If the individual holds a senior-manager-function-holder role, include their fca-fs-register-individual claim here too.

curl "https://api.griffin.com/v0/organizations/${ORGANIZATION_ID}/legal-persons" \
  -H "Authorization: GriffinAPIKey $GRIFFIN_API_KEY" \
  -H 'Content-Type: application/json' \
  -d \
'{
  "display-name": "PATEL, Amir",
  "legal-person-type": "individual",
  "claims": [
    {
      "claim-type": "individual-identity",
      "given-name": "Amir",
      "surname": "Patel",
      "date-of-birth": "1978-09-22"
    },
    {
      "claim-type": "fca-fs-register-individual",
      "fca-individual-reference-number": "PRA12345"
    }
  ]
}'

Add role associations to the society

After creating the individual legal persons, link them to the society by adding role association claims. Submit these to the society's claims endpoint:

curl "https://api.griffin.com/v0/legal-persons/lp.njk7tIWvQJGPEFIdDmS9yQ/claims" \
  -H "Authorization: GriffinAPIKey $GRIFFIN_API_KEY" \
  -H 'Content-Type: application/json' \
  -d \
'{
  "claim-type": "senior-manager-function-holder",
  "legal-person-url": "/v0/legal-persons/lp.{individual-id}"
}'

curl "https://api.griffin.com/v0/legal-persons/lp.njk7tIWvQJGPEFIdDmS9yQ/claims" \
  -H "Authorization: GriffinAPIKey $GRIFFIN_API_KEY" \
  -H 'Content-Type: application/json' \
  -d \
'{
  "claim-type": "role-titles",
  "legal-person-url": "/v0/legal-persons/lp.{individual-id}",
  "role-titles": ["Chief Executive Officer"]
}'

info

In these examples, you create the legal person and their claims in one go, but you can also create a legal person first and then add claims individually. For more detail on claims, see the API reference.

3. Run the verification

Retrieve your workflows

If you're onboarding a customer for the first time, you will need to retrieve your workflows in order to submit the verification. Retrieve and cache your workflow URLs.

Submit the verification

Submit the corporation legal person for verification:

curl 'https://api.griffin.com/v0/legal-persons/lp.njk7tIWvQJGPEFIdDmS9yQ/verifications' \
  -H "Authorization: GriffinAPIKey $GRIFFIN_API_KEY" \
  -H 'Content-Type: application/json' \
  -d '{"workflow-url": "/v0/workflows/wf.Ul-1r4gRWfOFxHJsHWghcA"}'

A successful response will look like this. Grab the verification-url for monitoring later.

{
  "created-at": "2024-02-10T10:47:51.959Z",
  "display-name": "Northside Credit Union",
  "legal-person-type": "corporation",
  "legal-person-url": "/v0/legal-persons/lp.njk7tIWvQJGPEFIdDmS9yQ",
  "updated-at": "2024-02-10T10:47:51.959Z",
  "verification-status": "pending",
  "verification-url": "/v0/verifications/vn.BhpS_dCqFKRYXa8d457fgA",
  "workflow-url": "/v0/workflows/wf.Ul-1r4gRWfOFxHJsHWghcA"
}

4. View the verification outcome and onboarding decision

Verification status

The verification has successfully completed when verification-status reaches checks-complete. You can track this by:

Polling the verification-url
Listening for verification-updated webhook events

Example response:

{
  "created-at": "2024-02-11T10:47:51.959Z",
  "display-name": "Northside Credit Union",
  "legal-person-type": "corporation",
  "legal-person-url": "/v0/legal-persons/lp.njk7tIWvQJGPEFIdDmS9yQ",
  "updated-at": "2022-08-15T10:48:03.215Z",
  "verification-status": "checks-complete",
  "verification-url": "/v0/verifications/vn.BhpS_dCqFKRYXa8d457fgA",
  "workflow-url": "/v0/workflows/wf.Ul-1r4gRWfOFxHJsHWghcA"
}

Verification statuses explained

Status	Description
`pending`	Verification has been created but processing has not yet begun
`in-progress`	Verification checks are actively being performed
`failed`	An internal system error has occurred during verification
`checks-declined`	Verification was terminated early due to failing one or more workflow checks
`checks-complete`	Verification has successfully completed all required checks

Decision process

After reaching checks-complete, the system will either:

Generate an automated decision
Refer the application for manual review (followed by a manual decision)

Monitor decisions by:

Polling the legal-person-decisions-url endpoint
Listening for decision-created webhook events

View on the legal person

Both the verification status and the decisions can be seen in context on the legal person entity.

curl 'https://api.griffin.com/v0/legal-persons/lp.njk7tIWvQJGPEFIdDmS9yQ' -H "Authorization: GriffinAPIKey $GRIFFIN_API_KEY"

The response will include application-status and also the latest-decision when one exists:

{
  "latest-decision": {
    "verification-url": "/v0/verifications/vn.BhpS_dCqFKRYXa8d457fgA",
    "decision-outcome": "accepted",
    "decision-maker": "user",
    "decision-notes": "No red flags here",
    "decision-user-url": "/v0/users/ur.ICAgICAgICAgdXNlci1pZA",
    "created-at": "2024-08-11T10:47:51.959Z"
  },
  "display-name": "Northside Credit Union",
  "application-status": "accepted",
  "status-changed-at": "2024-02-11T10:47:51.959Z",
  "created-at": "2024-02-10T10:47:51.959Z"
}

Once you have an accepted decision, you're good to go 🎉

What's next?

Open an account! See Types of bank accounts to get started.

Process overview​

1. Capture the customer information​

Society information​

Governing body member and senior manager information​

2. Create the legal persons​

Create the society legal person​

Create governing body member and senior manager legal persons​

Add role associations to the society​

3. Run the verification​

Retrieve your workflows​

Submit the verification​

4. View the verification outcome and onboarding decision​

Verification status​

Verification statuses explained​

Decision process​

View on the legal person​

What's next?​

Process overview

1. Capture the customer information

Society information

Governing body member and senior manager information

2. Create the legal persons

Create the society legal person

Create governing body member and senior manager legal persons

Add role associations to the society

3. Run the verification

Retrieve your workflows

Submit the verification

4. View the verification outcome and onboarding decision

Verification status

Verification statuses explained

Decision process

View on the legal person

What's next?