Reliance: Onboard a society

Reliance is for use by regulated firms only. Onboarding via Reliance is only available by API.

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

You complete customer due diligence (CDD) using your own tools and processes, and then send us the information we need. You must also attest that you have verified your customer's identity in line with the standards set by the Joint Money Laundering Steering Group (JMLSG).

Once you've submitted the required information, we validate that the required fields are present, screen the society and its governing body members and senior managers against sanctions lists, and assess whether the customer falls within our risk appetite based on industry and risk rating.

caution

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

Process overview

There are four steps to onboarding a society using Reliance:

1. Choose your workflow
2. Capture the customer information
3. Submit the application
4. Receive a decision

1. Choose your workflow

Find the relevant workflow for your customer type. See Workflows for how to retrieve and cache your workflow URLs.

2. 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	✓
FCA Firm Reference Number	fca-fs-register-firm	Required when society-type is credit-union or building-society
Business size	business-size	✓
SIC codes	sic-codes	✓
Tax residencies	tax-residencies	✓
External risk rating	external-risk-rating	✓
Verification attestation	reliance-verification	✓

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

Governing body member and senior manager information

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

Information	Claim	Required
Full name	individual-identity	✓
Date of birth	individual-identity	✓
Residential address	individual-residence	✓
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)
FCA Individual Reference Number	fca-fs-register-individual	Required when individual holds a senior-manager-function-holder role
Role titles	role-titles	✓ (required for every linked individual)
Verification attestation	reliance-verification	✓

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.
• While optional, providing middle names helps reduce false positives in sanctions checks.

Attesting to verification

In addition to submitting the above information, you must also attest that you have verified both the society information and the identities of the governing body members and senior managers. To do this, use the reliance-verification claim — once on the society and once on each linked individual — and enter one or more of the following reliance-verification-methods:

Verification method	Description
electronic	The customer was verified using electronic sources (credit reference agency)
physical	The customer provided documentation in person
manual-biometric	Government documentation cross-referenced with a selfie and verified by a third party
manual-document	The customer supplied documentation e.g. a passport copy and address document
jmlsg	Attest that the verification method used was in line with JMLSG standards

3. Submit an application

To submit an application, make a request to:

POST https://api.griffin.com/v0/organizations/{organization-id}/onboarding/applications

You will need to provide the claims relevant to the society, following the Claims API reference for the subject-profile (the society) and related-profiles (governing body members and senior managers).

Example application

{
  "workflow-url": "/v0/workflows/wf.Ul-1r4gRWfOFxHJsHWghcA",
  "subject-profile": {
    "display-name": "Northside Credit Union",
    "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": "fca-fs-register-firm",
        "fca-firm-reference-number": "123456"
      },
      {
        "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": "reliance-verification",
        "reliance-verification-methods": ["electronic", "manual-document"],
        "reliance-verification-standard": "jmlsg"
      }
    ]
  },
  "related-profiles": [
    {
      "display-name": "PATEL, Amir",
      "subject-association": {
        "senior-manager-function-holder": {},
        "role-titles": ["Chief Executive Officer"]
      },
      "claims": [
        {
          "claim-type": "individual-identity",
          "given-name": "Amir",
          "surname": "Patel",
          "date-of-birth": "1978-09-22"
        },
        {
          "claim-type": "individual-residence",
          "building-number": "19",
          "street-name": "Example Street",
          "city": "Test Town",
          "postal-code": "TE1 2ST",
          "country-code": "GB"
        },
        {
          "claim-type": "fca-fs-register-individual",
          "fca-individual-reference-number": "PRA12345"
        },
        {
          "claim-type": "reliance-verification",
          "reliance-verification-methods": ["manual-biometric", "manual-document"],
          "reliance-verification-standard": "jmlsg"
        }
      ]
    },
    {
      "display-name": "JOHNSON, Talia",
      "subject-association": {
        "governing-body-member": {},
        "role-titles": ["Chairperson"]
      },
      "claims": [
        {
          "claim-type": "individual-identity",
          "given-name": "Talia",
          "surname": "Johnson",
          "date-of-birth": "1985-03-15"
        },
        {
          "claim-type": "individual-residence",
          "building-number": "21",
          "street-name": "Example Street",
          "city": "Test Town",
          "postal-code": "TE1 2ST",
          "country-code": "GB"
        },
        {
          "claim-type": "reliance-verification",
          "reliance-verification-methods": ["manual-biometric", "manual-document"],
          "reliance-verification-standard": "jmlsg"
        }
      ]
    }
  ]
}

tip

If an individual holds both a governing body role and a senior manager function, include both keys on subject-association, for example {"governing-body-member": {}, "senior-manager-function-holder": {}, "role-titles": ["Chief Executive Officer"]}.

A successful response body looks like this:

{
  "onboarding-application-url": "/v0/onboarding/applications/oa.b25ib2FyZGluZy1hcHBsaQ",
  "onboarding-application-status": "submitted"
}

Monitoring the application

To monitor the application status, either poll the onboarding-application-url or create a webhook and listen for the onboarding-application-created and onboarding-application-updated events.

Once an application has been submitted, it will register the subject and related profiles and the status will update to processing. A legal-person-url and verification-url will be added to the application, as shown below:

{
  "onboarding-application-url": "/v0/onboarding/applications/oa.b25ib2FyZGluZy1hcHBsaQ",
  "created-at": "2019-08-24T14:15:22Z",
  "workflow-url": "/v0/workflows/wf.Ul-1r4gRWfOFxHJsHWghcA",
  "onboarding-application-status": "processing",
  "legal-person-url": "/v0/legal-persons/lp.IGxlZ2FsLXBlcnNvbi1pZA",
  "verification-url": "/v0/verifications/vn.IHZlcmlmaWNhdGlvbi1pZA"
}

4. Receive a decision

When the onboarding-application-status moves to complete, a decision of accepted or declined will be added to the application.

A successful response body for a complete application that has been accepted looks like this:

{
  "onboarding-application-url": "/v0/onboarding/applications/oa.b25ib2FyZGluZy1hcHBsaQ",
  "created-at": "2019-08-24T14:15:22Z",
  "workflow-url": "/v0/workflows/wf.Ul-1r4gRWfOFxHJsHWghcA",
  "onboarding-application-status": "complete",
  "legal-person-url": "/v0/legal-persons/lp.IGxlZ2FsLXBlcnNvbi1pZA",
  "verification-url": "/v0/verifications/vn.IHZlcmlmaWNhdGlvbi1pZA",
  "decision": "accepted"
}

If the verification process fails, the application status will update to errored. You can query the verification-url for more detail:

GET https://api.griffin.com/v0/verifications/{verification-id}

What's next?

Once you have an accepted decision, you can open a bank account. See Types of bank accounts to get started.