Before the first payout, a provider asks for your company's registration and articles. It also wants your address, your directors and each beneficial owner with ID. EU and US rules draw the owner line at about 25%. Nigeria's CBN rules use 5% instead. An invoice backs one payment. It does not show who owns or runs your company.
General information, not legal advice. Check current rules with your provider and your own counsel.
This guide is for PSPs, platforms and companies that pay suppliers or sellers abroad. If you onboard merchants yourself, see when a provider can rely on your KYC for sub-merchants.
What KYB documents does a payment provider ask for?
KYB means know your business. It is customer due diligence when the customer is a company. The global base is the FATF Recommendations, updated June 2026. Recommendation 10 and its note list what a firm must know about a company.
| What the provider checks | Typical document | Rule behind it |
|---|---|---|
| The company exists | Certificate of incorporation or of good standing | FATF note to Recommendation 10 |
| What binds it | Memorandum and articles of association | FATF note to Recommendation 10 |
| Where it sits | Registered office, and the main place of business if different | FATF note, EU Regulation 2024/1624 |
| Who runs it | Names of directors and senior managers | FATF note, CBN 2022 Regulations |
| Who owns it | Shareholder list and each beneficial owner's ID | FATF Recommendation 10, CBN 2022 Regulations |
| Who signs for it | Board resolution or other authority for the representative | CBN 2022 Regulations |
| Why it wants the service | The purpose and intended nature of the relationship | FATF Recommendation 10 |
Nigeria adds local detail. The CBN's AML/CFT/CPF Regulations were made on 12 May 2022. They define a company's identity. It includes the CAC registration number, the tax ID and the directors with their BVN. For some unquoted companies, the provider obtains the incorporation certificate and address evidence. It also obtains the list of shareholders and directors, from an official or independent source.
The EU writes a similar list into law from 10 July 2027. Regulation (EU) 2024/1624, Article 22, asks for the legal form, name and registered office. It also asks for the legal representatives and, where available, the registration number. It adds anyone holding shares or a directorship as a nominee.
Who counts as a beneficial owner?
A beneficial owner is the person who in the end owns or controls the company. The ownership line depends on the market. So does the date the rule applies.
| Market | Rule, date | Ownership line | Control counts too |
|---|---|---|---|
| FATF standard | Recommendation 10 and its note, June 2026 edition | A threshold is one option, for example more than 25% | Yes, then a senior managing official |
| EU, until 9 July 2027 | Directive (EU) 2015/849, Article 3(6) | 25% plus one share, or more than 25%, as an indication | Yes |
| EU, from 10 July 2027 | Regulation (EU) 2024/1624, Article 52 | 25% or more, direct or indirect | Yes, tested in parallel |
| US covered institutions | 31 CFR 1010.230, last amended 2017 | 25% or more of the equity | Yes, one person with significant control |
| Nigeria | CBN AML/CFT/CPF Regulations 2022, regulation 21(5) | 5% interest or more | Yes |
Three details change the work. The EU regulation multiplies indirect stakes along each chain, then adds the chains. It also lets the Commission set a lower line for higher-risk company types. That line is at most 15%, or under 25% if risk justifies it. The assessment is due by 10 July 2029.
In the US, the rule covers banks, securities brokers, futures firms and mutual funds. A FinCEN order of 13 February 2026 eased re-checks. These institutions identify owners when a company first opens an account. After that, they may limit re-checks to two cases. One is when facts put the data in doubt. The other is when risk calls for it. A proposed revision of the rule reached OMB on 17 September 2026. It was still pending review on 27 October 2026.
When an owner is another company, the provider looks behind it. Nigeria's CBN rules say so for higher-risk private companies. Owners can also live in a different country from the company. A platform raised this in one call about its own clients. Each of those people still needs an identity check.
Why is an invoice alone not enough?
KYB and the invoice answer different questions. KYB says who you are. The invoice says what one payment is for.
FATF Recommendation 10 keeps the two apart. Points (a) and (b) cover the customer and its beneficial owners. Point (c) covers the purpose of the relationship. Point (d) covers each transaction. Transactions must fit what the firm knows of the customer, its business and risk. Where needed, that includes the source of funds. So the provider reads each invoice against the company file.
| Entity file (KYB) | Payment file | |
|---|---|---|
| Answers | Who owns and runs the company | What this payment is for |
| When | At onboarding, then on review | Per payment or per supplier |
| Typical documents | Registration, articles, owners' IDs | Invoice, supply or service agreement |
| FATF Recommendation 10 | Points (a), (b) and (c) | Point (d) |
Call notes show what this means in practice:
- One PSP described its merchant KYB. It collects owners' IDs, incorporation papers and each merchant's service agreement. It also asks for business invoices.
- Another PSP said its document list depends on each client's risk rating. It asks financial-sector clients for source of funds, but not always traders.
- One provider onboards a platform's clients in the background for third-party payouts. It reuses the KYC documents the platform holds. It asks the platform for anything critical that is missing.
If your merchants collect in their own name, the same file backs named USD accounts. It also backs payments on behalf of your merchants.
How long does KYB take?
The rules fix when checks must be done. Review times come from practice.
FATF Recommendation 10 asks for verification before or during the start of the relationship. Countries may allow it soon after, if risks are managed and a delay would disrupt business. Nigeria's CBN rules allow completion after the start in three cases. One is when it can be done within 48 hours.
Published guides give ranges, not rules. One KYB guide puts manual reviews at 3 to 7 days per merchant. It says automation can cut that to under 24 hours. Another says two days to several weeks. Its variables are ownership layers, registry access, owner availability and screening hits.
KYB does not restart at each payout. Nigeria's CBN rules do not require new identity checks at every transaction. One exception is a suspicion that the data is incomplete or has changed. Another is a suspicion of money laundering. A payment of significant value can also trigger fresh due diligence. Each payment is still checked against the file.
What slows KYB down?
- Layered ownership. Each holding company in the chain must be traced to people. One KYB guide calls this the step that takes the time.
- Owners abroad. An owner in another country still needs an ID check. One unreachable owner holds the file, says one KYB guide.
- Documents that disagree. The registry, the shareholder agreement and the cap table can each say something different. Reconciling them takes letters back and forth.
- Slow registries. One KYB guide calls registry access the largest source of variance in turnaround.
- Screening hits. Common names match sanctions or PEP lists. A reviewer must clear each match by hand.
- A second review. In one call, a provider said partner reviews of each file can take one to two weeks. It prefers reliance for that reason.
In another call, a platform said KYB took the most time when it onboarded with other providers.
How do you prepare a KYB pack?
Build the pack before the first call. Ask the provider for its exact list, then match it.
- Certificate of incorporation and a recent registry extract or status report.
- Memorandum and articles of association.
- Proof of the registered and trading address.
- Register of directors and shareholders, with an ownership chart down to people.
- ID for each director and each beneficial owner above the provider's line.
- Board resolution naming who signs for the company.
- Tax ID, plus your licence if you are regulated.
- A one-page note on what you sell, to whom, and where funds come from.
- For each payment, the invoice and the supply or service agreement behind it.
FAQ
What documents are needed for KYB?
Five groups. Proof the company exists, its articles, its address, its directors and its beneficial owners with ID. Nigerian rules add the tax ID and the directors' BVN.
Who counts as a beneficial owner in KYB?
25% is the usual line. US rules use 25% or more, as will EU rules from 10 July 2027. Nigeria's CBN rules use 5%. A person who controls the company also counts.
Is an invoice enough for a cross-border payout?
No. An invoice explains one payment. The provider still needs to know who owns and runs the paying company.
How long does KYB take?
Two days to several weeks, says one KYB guide. Another puts manual reviews at 3 to 7 days per merchant. A complete file moves faster.
Does KYB repeat for every payout?
No. Nigeria's CBN rules do not require new identity checks at each transaction. Doubts about the data or a suspicion of money laundering are exceptions.
For PSPs and platforms
Paying suppliers or sellers across Africa and beyond? Talk to our team. Go live in about six weeks (two-week integration, compliance in parallel). Nilos Canada Ltd is registered with FINTRAC as a money services business (MSB C100000178). See how compliance works at Nilos, and what Nilos builds for PSPs and fintechs.