united-kingdom legal-terms currency payment
KYC (Know Your Customer) Verification Between Two Businesses
<p>I want to add a payment service to an existing business which has already verified its customers (id, proof of address). The service is not like Stripe, because they only abstract the connection with the banks' APIs. It is a business on its own, a smart currency exchange system, so it is required to apply KYC. More on that <a href="http://www.legislation.gov.uk/uksi/2017/692/pdfs/uksi_20170692_en.pdf" rel="nofollow noreferrer">here</a>.</p>

<p>Basically, if business A has already verified its customers, can it pass data to business B to process the payment, with no additional KYC required for B? The user will be allowed to make a payment via B to only pay for A’s services, therefore the funds will only go to one of their bank accounts. Logically, money laundering is out of question here, as A is already regulated, but I’m not completely sure.</p>

<p>Of course, prior to confirm the payment, there will be a "Do you agree to share details with B to make the payment" type of question.</p>

<p>Superficially, this looks like a viable business model. You would want to check the UK regulations on KYC to see if it addresses these kinds of issues specifically. If there was a safe harbor provision, you would want to tailor your agreement to fit it.</p>
