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Add corporate related entities

A Corporate-related is a Physical or a Moral entity linked to the company under registration. Depending on the type of Corporate Related, requested information will be different.

You must declare all Directors (Physical or Moral Entity) and all Shareholders with >= 25% ownership (UBO).

In some specific case, LinkCy could request you to register Shareholders with >=10% ownership. This request will be triggered by the compliance team using "isExtendedUbos": true.

Here is an example of a sharholding structure, which will be used in the following chapters.
You can find other examples at the end of this page.

40%
90%
25%
5%
Corporate MyCompany
Company ShareholdingCompany
UBO Bob
UBO Alice
Director Charles

Directors

You will be requested you to do a FULL_KYC for at least one of the director (by default it's the first one you register). In most of the cases, it will be the Account Owner.

For other Directors, we will only ask you to do a DOC_ONLY KYC. The main difference is that DOC_ONLY do not contains Selfie & Liveness.

When LinkCy detect that KYC is not requested, the "kycInfo.type" value will be "NOT_REQUIRED"

Directors can also be Shareholders. LinkCy needs to make a Diligence Review on all UBOs of the Corporate. A UBO is an Ultimate Beneficial Owner who own more than 25% of shares of a company or legal entity. He is always a Physical Person.

In example above, "Charles" is a director (and the only one). He is not an UBO (owning only 5%), but as he is the first director, he will have to perform a Full KYC.

Direct Shareholders

If a corporate-related owns shares of a company directly, you need to provide this information by filling the value in directSharesPercentage. In the example above, "Alice" is a direct shareholder and UBO (25% of "MyCompany").
In this case, value of finalSharesPercentage will be the same than directSharesPercentage and the layer will be 1.

"shareInfo": {
  "directSharesPercentage": 25,
  "finalSharesPercentage": 25, 
  "layer": 1
},

All UBOs will have to perform a Doc-only KYC. "Alice" is a UBO and will have to perform a Doc-only KYC

Indirect Shareholders

If a corporate-related doesn't owns share directly, you have to declare intermediate companies.
In the example above, "Bob" is an indirect shareholder, through "ShareholdingCompany".

You have to register "ShareholdingCompany" as a Direct Shareholder and set directSharesPercentage to 40%.

"sharesInfo": {
  "directSharesPercentage": 40
},

You will get :

"shareInfo": {
  "directSharesPercentage": 40,
  "finalSharesPercentage": 40, 
  "layer": 1
},

Then, you need to declare "Bob" as a indirect Shareholder, holding 90% of "ShareholdingCompany". "Bob" is a UBO and will have to perform a Doc-only KYC

"sharesInfo": {
  "directSharesPercentage": 90,
  "ownedCorporateId": "Id of ShareholdingCompany"
},

You will get :

"shareInfo": {
  "ownedCorporate": {
    "id": "Id of ShareholdingCompany"
},
  "directSharesPercentage": 90,
  "finalSharesPercentage": 36,
  "layer": 2
},

"finalSharesPercentage": 36 indicates the shares of "Bob" in "MyCompany".

Special UBO

Sometimes, no one owns at least 25% of a company. In this case, a Physical Person is declared as a UBO even with less than 25% of ownership. The Compliance team will check and define according to your documentation a Physical Person with : "isSpecialUbo": true. Check Example C3 below for en example.

Shares Management

To manage complex usecases and shareholding structures or correct mistakes, you can also directly manages shares between corporate related, using the following endpoint :

  • "Create a share"
  • "Delete a share"
  • "Update a share"
  • "Get share's information"

These endpoints allow you to create or update the shareholding structure when corporate-related are already created.
The most useful case is when a corporate-related has multiple shares in the shareholding structure. Indeed the regular endpoint doesn't allow to create this kind of structure.
Check Example C4 below for an example.

This also allows to correct the shareholding structure if you made mistakes, or if it changes during time.

Convoluted examples

Example C1

40%
50%
50%
100%
50%
0%
Corporate MyCompany
Company CorpA
Alice
Company CorpB
Company CorpC
Charles
AccountOwner Bob

Here you have to :

  • Declare CorpA as a direct sharholder, with directSharesPercentage : 40
  • Declare Alice as an indirect sharholder, with directSharesPercentage : 50 and ownedCorporateId : "CorpA"
  • Declare CorpB as a direct sharholder, with directSharesPercentage : 50
  • Declare CorpC as an indirect sharholder, with directSharesPercentage : 100 and ownedCorporateId : "CorpB"
  • Declare Charles as an indirect sharholder, with directSharesPercentage : 50 and ownedCorporateId : "CorpC"

At the End :

  • Alice has finalSharesPercentage: 20 and then is not considered as UBO. No KYC required.
  • Charles has finalSharesPercentage: 25 and is UBO. Doc-only KYC required.
  • Bob has already been declared as AccountOwner (during Corprote creation) and has no shares.

Example C2

20%
20%
25%
20%
100%
Corporate MyCompany
AccountOwner and Director Alice
Director Charles
Company CorpA
Director David
Bob

Here you have to :

  • Declare Charles as a director and direct sharholder, with directSharesPercentage : 20
  • Declare CorpA as a direct sharholder, with directSharesPercentage : 25
  • Declare Bob as an indirect sharholder, with directSharesPercentage : 100 and ownedCorporateId : "CorpA"
  • Declare David as a director and direct sharholder, with directSharesPercentage : 20

At the End :

  • Alice has already been declared as AccountOwner (during Corprote creation) and has finalSharesPercentage: 20. As the first director, Full KYC is required.
  • Charles has finalSharesPercentage: 20 and is not UBO. As he is director but not the 1st one, Doc-only KYC is required.
  • Bob has finalSharesPercentage: 25. He is then UBO and Doc-only KYC is required.
  • David has finalSharesPercentage: 20 and is not UBO. As he is director but not the 1st one, Doc-only KYC is required.

Example C3

20%
20%
25%
20%
50%
Corporate MyCompany
AccountOwner Alice
Charles
Company CorpA
David
Bob

Here you have to :

  • Declare Charles as a direct sharholder, with directSharesPercentage : 20
  • Declare CorpA as a direct sharholder, with directSharesPercentage : 25
  • Declare Bob as an indirect sharholder, with directSharesPercentage : 50 and ownedCorporateId : "CorpA"
  • Declare David as a direct sharholder, with directSharesPercentage : 20

At the End :

  • Alice has already been declared as AccountOwner (during Corprote creation) and has finalSharesPercentage: 20, and is not UBO.
  • Charles has finalSharesPercentage: 20 and is not UBO.
  • Bob has finalSharesPercentage: 12.5 and is not UBO.
  • David has finalSharesPercentage: 20 and is not UBO.

In this case, no UBO has been identified. LinkCy will then declare one of them "SpecialUBO" (usualy the AccountOwner), and he will be required to do a Doc-only KYC.

Example C4

40%
50%
50%
100%
50%
50%
0%
Corporate MyCompany
Company CorpA
Alice
Company CorpB
Company CorpC
Charles
AccountOwner Bob

This is based on Example C1, but with Alice also having shares in CorpC.

Here you have to :

  • Declare CorpA as a direct sharholder, with directSharesPercentage : 40
  • Declare Alice as an indirect sharholder, with directSharesPercentage : 50 and ownedCorporateId : "CorpA"
  • Declare CorpB as a direct sharholder, with directSharesPercentage : 50
  • Declare CorpC as an indirect sharholder, with directSharesPercentage : 100 and ownedCorporateId : "CorpB"
  • Declare Charles as an indirect sharholder, with directSharesPercentage : 50 and ownedCorporateId : "CorpC"
  • Declare the share of Alice in CorpC as indirect sharholde, with corporateRelatedId : "Alice", ownedCorporateId : "CorpC" and percentage : 50

At the End :

  • Alice has finalSharesPercentage: 45 and is now considered as UBO. KYC required.
  • Charles has finalSharesPercentage: 25 and is UBO. KYC required.
  • Bob has already been declared as AccountOwner (during Corprote creation) and has no shares.

You can also declare Alice as indirect shareholder through CorpC and then Create the share of Alice in CorpA, result will be the same.