docs(guides): tighten KYC/KYB scope, fix doc list, add beneficiary review#25
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docs(guides): tighten KYC/KYB scope, fix doc list, add beneficiary review#25diegopereira90 wants to merge 1 commit intomainfrom
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Cross-checked the KYC/KYB guide against the actual fx-account request
DTOs and the dev-utils DocumentType enum. Three categories of fix:
1. Scope clarification — KYC/KYB applies to the account owner; end-user
beneficiaries (the parties marketplaces pay out to) go through a
separate, rail-tuned compliance review documented in a new guide.
2. Doc list tightening — every document bullet now shows the canonical
DocumentType value. Removed three sources of confusion:
- Bullets that lumped distinct documents (Articles of Association
vs. board-election minutes, PJ partner docs vs. statements).
- Duplicate listings of the same document (AML/CTF and PLD/FT are
the same thing in two languages).
- Process steps mixed in with documents (Pre-approval from
compliance is internal, not an upload).
3. UBO field table — added phone, email, isLegalRepresentative, which
are required fields on UBORequest but were missing from the table.
Removed "Email address and phone number" from the document list,
where they don't belong.
Three follow-ups not covered here are tracked as issues in their
respective repos (linked in the PR description).
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marioalvial
approved these changes
May 8, 2026
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Summary
Cross-checked
guides/kyc-kyb.mdxagainst the actual fx-account request DTOs and dev-utilsDocumentTypeenum. Three categories of fix:1. Scope clarification
The opening paragraph now makes explicit that KYC/KYB applies to the account owner and the UBOs that ultimately control them. The end-user beneficiaries that marketplaces pay out to go through a separate rail-tuned compliance review, documented in a new sibling guide:
guides/beneficiary-compliance-review.mdx— strictly factual about today's behaviour. Describes the data the marketplace submits, the checks Trace runs (sanctions/PEP screening + rail-specific verification), and the marketplace's compensating-control responsibility for primary KYC of its own end-users. No forward-looking claims.2. Doc list tightening
Every document bullet now shows the canonical
DocumentTypevalue to upload. Three sources of confusion removed:ARTICLES_OF_ASSOCIATION(articles/bylaws) andSIGNING_AUTHORITY_PROOF(board-election minutes). Same treatment for "Articles of association of any corporate shareholder" →PJ_PARTNER_DOCUMENTS+PJ_PARTNER_FINANCIAL_STATEMENT.AML_POLICY).For Brazilian government IDs, the mapping is now explicit: RG →
ID_CARD, CNH →DRIVER_LICENSE, RNM →RESIDENCE_PERMIT. (MRE was deliberately omitted — its mapping is ambiguous; needs compliance input before publishing.)3. UBO field table fix
Added three fields required by
UBORequestthat were missing from the table:phoneemailisLegalRepresentativefalse.trueif the UBO can sign on behalf of the company."Email address and phone number" was previously listed as a document — moved into the field table where it belongs.
Follow-ups (not in this PR)
Three items surfaced by the audit that require code/contract decisions, not doc fixes. Tracked separately:
#98RFC: Travel Rule and beneficiary-side compliance for PIX and Crypto rails. Compares today's beneficiary checks against PIX (BACEN) and Crypto (FATF Travel Rule, BR Lei 14.478, OFAC) requirements; lists candidate action items without prescribing phasing.#148Onboarding schema gaps for KYB/KYC fields not currently captured. PSP operational details and individual extended fields (FATCA, marital status, profession, income) — should they live onOwnerRequestor be captured via partner-bank-specific forms uploaded as documents?#98Add DocumentType values for FATCA, CDD, and other compliance forms currently OTHER. Five candidateDocumentTypeadditions to discuss with compliance.The doc-only fixes here are intentionally narrow — they make today's guide accurate, while the three issues above carry the larger conversations that will produce future doc updates.
Test plan
python3 -c "import json; json.load(open('docs.json'))"— JSON valid after addingguides/beneficiary-compliance-reviewto the navigation.🤖 Generated with Claude Code