Outsourced: Onboard a sole trader

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 sole trader via Outsourced:

1. Capture the customer information
2. Create the legal person
3. Run the verification
4. View the verification outcome and onboarding decision

1. Capture the customer information

Sole trader information

Information	Claim	Required
Full name (given name)	individual-identity	✓
Middle name	individual-identity	Optional
Full name (surname)	individual-identity	✓
Date of birth	individual-identity	✓
Trading name	business-name	✓
Trading address	business-address	✓
Residential address	individual-residence	✓
Business type	business-type	✓
Industry code (SIC)	sic-codes	✓
Business size	business-size	✓
US citizen confirmation	us-citizen	✓
Tax residency/ies	tax-residencies	✓
Tax identifier number/s	tax-identification-numbers-by-country	✓
Risk rating	external-risk-rating	✓
Number of employees	Not captured	Optional
Balance sheet size	Not captured	Optional
Estimated annual turnover	Not captured	Optional

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.

2. Create the legal person

In the API, your customer is represented as a legal person, and each of the data points above represent one claim about them. Create an individual legal person to represent the sole trader and then add claims about them.

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": "SMITH, John - Trading as John'\''s Plumbing",
  "legal-person-type": "individual",
  "claims": [
    {
      "claim-type": "individual-identity",
      "given-name": "John",
      "surname": "Smith",
      "date-of-birth": "1980-05-20"
    },
    {
      "claim-type": "business-name",
      "business-name": "John'\''s Plumbing"
    },
    {
      "claim-type": "business-address",
      "business-address": {
        "building-number": "25",
        "street-name": "High Street",
        "city": "Manchester",
        "postal-code": "M1 1AA",
        "country-code": "GB"
      }
    },
    {
      "claim-type": "individual-residence",
      "building-number": "15",
      "street-name": "Oak Avenue",
      "city": "Manchester",
      "postal-code": "M2 2BB",
      "country-code": "GB"
    },
    {
      "claim-type": "sic-codes",
      "sic-codes": ["43220"]
    },
    {
      "claim-type": "business-size",
      "business-size": "micro"
    },
    {
      "claim-type": "us-citizen",
      "us-citizen?": false
    },
    {
      "claim-type": "tax-residencies",
      "tax-residencies": ["GB"]
    },
    {
      "claim-type": "tax-identification-numbers-by-country",
      "tins-by-country": {
        "GB": ["AB123456C"]
      }
    },
    {
      "claim-type": "external-risk-rating",
      "external-risk-rating": "low-risk"
    }
  ]
}'

A successful response will display the URL for the newly created legal person (e.g. /v0/legal-persons/lp.Kfd8_BhpSdCqFKRYXa8d45) in the response's Location header and in the response body. Save this URL for the next step.

info

In this example, 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 individual legal person for verification:

curl 'https://api.griffin.com/v0/legal-persons/lp.Kfd8_BhpSdCqFKRYXa8d45/verifications' \
  -H "Authorization: GriffinAPIKey $GRIFFIN_API_KEY" \
  -H 'Content-Type: application/json' \
  -d '{"workflow-url": "/v0/workflows/wf.G3yYmojQV32I814_5JLTEQ"}'

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

{
  "created-at": "2024-02-10T10:47:51.959Z",
  "display-name": "SMITH, John - Trading as John's Plumbing",
  "legal-person-type": "individual",
  "legal-person-url": "/v0/legal-persons/lp.Kfd8_BhpSdCqFKRYXa8d45",
  "updated-at": "2024-02-10T10:47:51.959Z",
  "verification-status": "pending",
  "verification-url": "/v0/verifications/vn.BhpS_dCqFKRYXa8d457fgA",
  "workflow-url": "/v0/workflows/wf.G3yYmojQV32I814_5JLTEQ"
}

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": "SMITH, John - Trading as John's Plumbing",
  "legal-person-type": "individual",
  "legal-person-url": "/v0/legal-persons/lp.Kfd8_BhpSdCqFKRYXa8d45",
  "external-risk-rating": "low-risk",
  "updated-at": "2022-08-15T10:48:03.215Z",
  "verification-status": "checks-complete",
  "verification-url": "/v0/verifications/vn.BhpS_dCqFKRYXa8d457fgA",
  "workflow-url": "/v0/workflows/wf.G3yYmojQV32I814_5JLTEQ"
}

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.Kfd8_BhpSdCqFKRYXa8d45' -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": "SMITH, John - Trading as John's Plumbing",
  "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.