KYC and KYB requirements

Information and documents required to onboard business and individual account owners.

Overview

Before an account can be activated, Trace FX must verify the identity of its owner and any beneficial owners. The verification model depends on the owner type:

• KYB (Know Your Business) applies to company-owned accounts (owner.type = COMPANY).
• KYC (Know Your Customer) applies to individually-owned accounts (owner.type = INDIVIDUAL) and to every beneficial owner (UBO) registered on a company-owned account.

KYC and KYB obligations apply to the account owner (your direct customer of Trace) and the UBOs that ultimately control a company customer. End-user beneficiaries — the parties a marketplace pays out to — go through a separate, rail-tuned compliance review described in Beneficiary compliance review.

Information is submitted as structured fields on POST /api/accounts; supporting documents are uploaded against POST /api/documents once the account exists. The exact document list varies per segment and per banking partner — the response from account creation returns requirements.currentlyDue (open) along with pendingVerification, errors, and satisfied for in-flight tracking.

Details

Business

Business onboarding covers companies that operate under one of the supported segments: standard companies (startups and PJs), payment service providers, crypto businesses, non-resident entities, funds, and exchange operators.

Common information for all business segments

These fields are submitted on the create-account request:

Field	Format	Notes
owner.legalName	string	Registered legal name on the company’s incorporation document.
owner.taxId.value	string	CNPJ for Brazilian companies; foreign tax identifier for non-residents.
owner.taxId.type	enum	CNPJ for Brazilian companies; the corresponding type for non-residents.
owner.industry	enum	Industry classification. See the create-account schema for the full list.
owner.incorporateDate	yyyy-MM-dd	Optional. Date of incorporation.
owner.address	object	Full registered address (line 1, city, state, country, postal code).

For each beneficial owner (UBO) registered via POST /api/accounts/{accountId}/ubos:

Field	Format	Notes
name	string	Full legal name.
taxId.value / taxId.type	string / enum	CPF for Brazilian residents; foreign tax ID for non-residents.
address	object	Residential address.
phone	string	Required. Mobile or contact number.
email	string	Required.
ownershipPercentage	number	Optional. Percentage of ownership.
isLegalRepresentative	boolean	Optional, defaults to false. true if the UBO can sign on behalf of the company.

Common documents for all business segments

These documents are required for every business segment. Each bullet shows the canonical documentType value for POST /api/documents:

• Articles of association or bylaws — registered and issued by the commercial registry (Junta Comercial in Brazil) — ARTICLES_OF_ASSOCIATION.
• Board-election minutes or equivalent proof of who can sign on behalf of the company — SIGNING_AUTHORITY_PROOF.
• Articles of association and financial statements of any corporate shareholder (PJ partner), if applicable — PJ_PARTNER_DOCUMENTS and PJ_PARTNER_FINANCIAL_STATEMENT.
• Dated and signed organizational chart, if the corporate structure has multiple layers — ORGANIZATIONAL_CHART.
• Annual revenue declaration, income statement (DRE), or balance sheet — signed by the accountant and the legal representative — FINANCIAL_STATEMENT.

For each beneficial owner:

• Government-issued photo ID — RG (ID_CARD), CNH (DRIVER_LICENSE), passport (PASSPORT), or RNM (RESIDENCE_PERMIT).
• Proof of residence issued within the last 90 days, accepted as PROOF_OF_ADDRESS (required by most partner banks).

Extra documents for payment service providers (PSPs)

PSPs (also referred to as “facilitadoras”) aggregate or facilitate payments on behalf of merchants. In addition to the common business documents, partner banks require:

• AML/CTF (PLD/FT) policies and manuals — AML_POLICY.
• A signed KYC form completed by the commercial officer — KYC_FORM. Operational details (number of employees, company website, annual revenue) are captured as part of this form today.
• A signed BaaS adhesion form, where applicable — BAAS_ADHESION_FORM.
• A merchants record sheet listing the PSP’s clients — OTHER with descriptive metadata.
• A CDD (customer due diligence) questionnaire signed by the compliance officer — OTHER with descriptive metadata.
• Power of attorney for any signatories acting on the company’s behalf — POWER_OF_ATTORNEY. Identity documents for those signatories follow the format described under “For each beneficial owner”.

Extra documents for crypto businesses

Crypto businesses submit the standard business package plus:

• A signed KYC form completed by the commercial officer — KYC_FORM.
• A signed BaaS adhesion form — BAAS_ADHESION_FORM.
• A crypto exposure questionnaire (CEQ) — OTHER with descriptive metadata.
• Information on the exchanges and platforms used to operate — OTHER with descriptive metadata.
• Evidence of source of funds — EVIDENCE_OF_SOURCE_OF_FUNDS.
• A description of the target audience, fundraising strategy, and marketing approach (for funds operating in crypto) — PROOF_OF_BUSINESS_ACTIVITY.

Extra documents for non-residents (CNR)

Non-resident entities (companies incorporated outside Brazil opening a CNR account) submit constitutional documents matching their legal form, all duly apostilled:

Legal form	Required constitutional documents
Corporation (Corp. / Inc.)	Articles of Incorporation, Bylaws, Share Register
Limited Liability Company (LLC)	Articles of Organization, Operating Agreement, Membership List
Limited (Ltd)	Memorandum of Association + Certificate of Incorporation, Articles of Association, Register of Members / Shareholders
Limited Liability Partnership (LLP)	Incorporation Document (UK) or Certificate of LLP (US), LLP Agreement, Register of Members

In addition:

• Financial statements signed by the accountant and the legal representative — FINANCIAL_STATEMENT.
• Corporate organizational chart identifying ultimate beneficial owners — ORGANIZATIONAL_CHART.
• AML/CTF policies — AML_POLICY.
• Operating licenses, where the entity handles third-party funds — PROOF_OF_REGULATORY_LICENSE.
• KYC form (KYC_FORM); due diligence form and account-opening forms specific to the partner bank — OTHER with descriptive metadata.
• Power of attorney granting authority to a Brazilian legal representative, when the foreign representative does not hold a CPF — POWER_OF_ATTORNEY.
• Wolfsberg questionnaire, when the entity is a financial institution — WOLFSBERG_QUESTIONNAIRE.

Individuals

Individual onboarding covers natural persons opening a Trace FX account in their own name.

Common information for individuals

These fields are submitted on the create-account request:

Field	Format	Notes
owner.firstName	string	Given name.
owner.lastName	string	Family name.
owner.taxId.value	string	CPF for Brazilian residents; foreign tax identifier otherwise.
owner.taxId.type	enum	CPF for Brazilian residents; the corresponding type otherwise.
owner.birthDate	yyyy-MM-dd	Optional. Date of birth.
owner.address	object	Full residential address (line 1, city, state, country, postal code).

Common documents for individuals

• Government-issued photo ID — RG (ID_CARD), CNH (DRIVER_LICENSE), passport (PASSPORT), or RNM (RESIDENCE_PERMIT). Some partner banks require the document to have been issued within the last 10 years.
• Proof of residence issued within the last 90 days — PROOF_OF_ADDRESS.
• Email address and phone number — collected via the authentication profile, not on the create-account body.
• Marital status, and the spouse’s full name and CPF when married — collected via partner-bank-specific forms.
• Tax identification number (NIF or equivalent) in the country of fiscal residence, for non-Brazilian residents — collected via partner-bank-specific forms.
• Proof of income — most recent income tax return, the last three pay stubs, or equivalent evidence — EVIDENCE_OF_SOURCE_OF_WEALTH.
• Profession, employer name, monthly income, and net worth, where the partner bank requires it — collected via partner-bank-specific forms.
• A FATCA form for individuals classified as foreign or with fiscal residence abroad — OTHER with descriptive metadata.

Related

• Open multi-currency account — end-to-end flow that submits owner details, uploads documents, and registers UBOs.
• Create an account — request schema for company and individual owners.
• Upload a document — endpoint used to submit each required document.
• Add a UBO — register a beneficial owner for a company-owned account.