Account holders
Individual (natural person) or legal entity (legal person) who owns and is responsible for the funds in a Swan account. Account holders must be located in a country where Swan offers accounts, as listed on the country coverage page.
Account holders can be individuals or companies (considered legal entities), and account holders can have as many Swan accounts as they need. In order for funds to be stored in a Swan account, they must be associated with an account holder.
As a result of the onboarding process, users become account holders.
Overview​
As a Partner and project owner, you choose who can have Swan accounts within your project. However, regulations require Swan to verify all of your account holders, and to keep track of them for the lifetime of the account.
Therefore, Swan verifies each user before the account holder and account objects are created in your Swan project. This verification, often referred to as Know Your Customer (KYC) or Know Your Business (KYB), is mandatory.
One benefit of working with Swan is that Swan is responsible for this process. However, if it is vital that you perform KYC and KYB processes yourself, please send an email to support@swan.io with a detailed explanation.
One account holder, multiple accounts​
For individual accounts, you can open multiple accounts for the same account holder. They'll complete a shorter onboarding process for each new account because they don't need to complete account holder verification again. Follow the guide to add additional individual accounts for an existing account holder.
For company accounts, however, Swan creates a new account holder for each account. Therefore, a full account holder verification is required if it's been more than three months since the last verification.
Account holder verification process​
The verification process for a new account holder is thorough, and Swan provides a streamlined process through which each account holder proves they're who they claim to be.
Account holders can access their account immediately after creation. However, while account holder verification is in progress, there are limitations on the account. IBANs might be issued before limitations are removed from the account.
The account holder verification process can include the following elements:
- Onboarding: Process is finalized for either an individual or a company, which creates a user, an account holder, an account, and an account membership linking the user to the account.
- Identification: User that opened the individual or company account completes identification with an ID document and a picture or video.
- Document collection: Swan collects required documents.
- Clarification: Swan might contact the user to clarify details from onboarding, identification, or document collection.
- First transfer: Certain users need to send a first transfer to their new Swan account.
- Review: Swan reviews all provided elements.
After Swan validates the review, the account holder is verified and their account receives its primary IBAN.
Statuses​
| Account holder verification status | Explanation |
|---|---|
NotStarted | Verification process hasn't started yet. The account holder's legal representative needs to complete identification before starting account holder verification. |
Pending | Swan is reviewing the account holder's information before activating or refusing the account. |
WaitingForInformation | Swan is waiting for information from the account holder, such as a first transfer, supporting documents, or something else. |
Verified | Swan verified the account holder and the process is complete |
Refused | Swan won't onboard this account holder |
Waiting for information status​
If the account holder verification status is WaitingForInformation, the account holder must meet one or more of the following requirements.
Call the API to learn which requirement they're missing.
| Requirement | Explanation |
|---|---|
FirstTransfer Required | Account holder needs to send a first transfer to their Swan account. |
LegalRepresentative DetailsRequired | More information is required about the account's legal representative, or about the account member acting as the legal representative with Power of Attorney. |
Organization DetailsRequired | More information is required about the organization. |
SupportingDocuments Required | Provide the requested supporting documents. |
TaxId Required | Provide the Tax ID for both the account holder and the organization. |
UboDetails Required | More information is required about the organization's ultimate beneficial owner or owners (UBO). |
Other | Swan contacts your account holder directly about additional requirements. |
First transfer​
Sending a first transfer to a user's Swan account can be requested after the user completes identification but before the account holder verification status changes to Verified.
Not all users are required to send a first transfer to be Verified.
Swan asks some users to send a first transfer as an additional verification measure.
Additionally, if your users complete certain identification processes in certain countries, a first transfer might be required by law.
Review the guide to request a first transfer for communication options.
A first transfer is always required for self-employed and individual accounts for which the account country is Germany, regardless of registration or residency.
Users must send first transfers from a bank account in their name. Transfers from third-party payment platforms like PayPal or Lydia aren't accepted.
Users can send any amount in the first transfer.
While there is technically no deadline for sending the transfer, the user's account is Limited until the transfer is validated.
First transfer and account holder verification status​
When Swan requests the first transfer, the account holder verification status changes to WaitingForInformation.
After the user sends their transfer, the account holder verification status changes to Pending while Swan checks the transfer source.
If transferred from an acceptable account, the account holder verification status changes to Verified.
Note that if the account used to send the first transfer is located outside of the European Economic Area (EEA), it may be subject to additional review.
If Swan requests supporting documents from the user as well, the account holder verification status remains WaitingForInformation after receiving the first transfer.
When the documents are received, the account holder verification status changes to Pending while Swan reviews them.
Sequence diagram​
This diagram details a common flow of how Swan, the account holder, and you interact during verification. Your integration might flow differently.