Entity Accounts
Opening a business account with Bakkt follows a process different to that of opening a regular customer account. Entities require a more comprehensive KYB process instead of an individual's KYC process due to the complexity of entities that are being evaluated. The entity itself and the owners of the entity must be reviewed to confirm they meet Bakkts compliance standards. Entity documents as well as individual documents are collected via API in an organized and secure manner. In certain cases the Bakkt automated entity onboarding flow will not work such as if an entity is owned by another entity. In this event please reach out to a Bakkt rep to understand the manual KYB process.
Continue reading to see the necessary steps, required documents, and other details needed to successfully open a business account.
To get started, please contact our support team at [email protected].
Account Opening API (For Entity Accounts)
The Account Opening API is used to enroll both individual accounts and entity accounts. Clients must ensure they include the entity object within the account request, along with all required fields within this object. This helps Bakkt collect relevant data for KYB screening and verification.
The Entity object is one object within the Account Opening API, for information on the other sections please refer to the Account Opening section of the documentation.
Entity Accounts
- Entity Legal Name
This field captures the official legal name of the entity as it is registered with relevant authorities. Accurate entity name records are required for regulatory compliance. - Entity Offerings
This field is required to help Bakkt understand the nature of the entity's business , products, services, and will help to tailor services accordingly. - Entity Tax ID
The national tax identifier for the country where the entity is incorporated is required to verify the entity’s legitimacy and ensure tax compliance. - Firm Annual Net Income
This field is required to assess transaction volumes and risk. - Firm Liquid Net Worth USD Range
This helps in evaluating the entity’s liquidity and financial capacity. - Daily Transaction Volume USD Range
Estimating the entity's transaction volume is required to aid in supporting the entity's trading activities and managing risk. - Entity Email Address
This field is required for communicating with the entity's account. - Entity Formation Date
This field gives Bakkt insight into the entity's operational history. - Operating Countries
List all countries where the entity operates in this field. This is required for Bakkt to enable operations within these jurisdictions and to inform strategic planning for future geographic expansion. - Registered Address
Inputting the official registered address of the entity is required for KYB verification. - Operating Address
This field is required to know where the entity conducts its business operations and may differ from the registered address. - Source of Currency
This describes the origin of the entity's virtual currency, which helps AML compliance and to ensure that the funds are obtained legally. - Daily Notional Trading Volume Range
This field indicates the expected daily trading volume in USD. This is required to ensure the platform is prepared to handle the volume. - Firm Total Net Worth USD Range
This field is required to provide a view into the entity's financial strength and risk assessment. - Investment Objective
This field gives Bakkt insight into the account's goals and helps with AML compliance to monitor trading patterns. - Entity Type
This field specifies the type of entity (e.g., corporate, partnership) and is required for understanding its legal and operational structure. - Operating Industry
This field details the industry in which the entity operates and is required to help Bakkt understand the nature of the entity's business. - Source of Funds
This field is required to identify the source of the entity’s fiat funds. This helps ensure that funds were obtained legally and are in compliance with AML regulations. - Investment Experience
This field describes the entity’s level of investment experience and helps with AML compliance to monitor trading patterns. - Subject to AML Regulations
This field indicates whether the entity is subject to Anti-Money Laundering (AML) regulations. This field is required for Bakkt to assess compliance requirements and ensure adherence to regulatory standards. - Active Wallet Address
This field is for inputting the entity's cryptocurrency wallet address. - Entity Phone Number
This field is required for communication with the entity’s account. - Entity Registration Status
This field specifies the registration status of the entity with any regulatory body. This field is required to ensure Bakkt's compliance with regulatory requirements and to verify the legal standing of the entity.
Roles
When enrolling an ENTITY
, the first owner on the account should always be designated the PRIMARY_OWNER
role, with all subsequent owners listed as BENEFICIAL_OWNER
. All owners on an entity account must be individuals. There are numerous roles available, each with specific responsibilities and permissions. Below is a brief description of each role:
- AUTHORIZED_AGENT: An individual granted authority to act on behalf of the entity or account holder.
- AUTHORIZED_MEMBER: A designated member with specific permissions within an entity or organization.
- AUTHORIZED_OWNER: An owner who has been given explicit authority to make decisions and manage the account.
- BENEFICIAL_OWNER: A person who enjoys the benefits of ownership even though the title is in another name.
- BENEFICIARY: An individual designated to receive benefits or assets from a trust, will, or insurance policy.
- CUSTODIAN: A person or institution that manages and safeguards assets on behalf of another.
- EDUCATION_BENEFICIARY: A person designated to receive educational benefits from an education savings account.
- EDUCATION_MANAGER: An individual responsible for managing an education savings account.
- EXECUTOR: A person appointed to carry out the terms of a will.
- GUARDIAN_CONSERVATOR: An individual appointed to manage the affairs of a minor or incapacitated person.
- INTERNAL_POWER_OF_ATTY: A designated person within an organization granted power of attorney to act on behalf of the entity.
- INITIAL_DEPOSITOR: The individual who makes the first deposit into an account.
- JOINT_OWNER: An individual who shares ownership of an account or asset with one or more persons.
- MINOR_OWNER: An owner who is legally underage and requires a guardian or custodian to manage the account.
- PRIMARY_OWNER: The main individual responsible for the account, typically with full control and decision-making power.
- POWER_OF_ATTY: A person given legal authority to act on behalf of another person in financial or legal matters.
- SOLE_PROPRIETOR: An individual who owns and operates a business alone.
- TRADING_AUTHORITY: An individual authorized to make trades and manage investment activities on behalf of the account holder.
- TREASURER: An individual responsible for overseeing the financial operations and management of an entity or organization.
- TRUSTEE: A person or organization that holds and manages assets for the benefit of another under a trust agreement.
- TRUSTED_CONTACT: A person designated to be contacted in case of concerns about the account holder’s well-being or activities.
Know-Your-Business (KYB) Screening
Bakkt is partnered with a preferred vendor to preform Know-Your-Business (KYB) checks. To ensure that all business accounts comply to high standard of compliance and regulations, Bakkt will collect and verify essential information and documents to comply with the Bank Secrecy Act, Anti-Money Laundering regulations, and U.S. Treasury’s Office of Foreign Assets Control requirements. It is the clients responsibility to notify Bakkt of any changes to the beneficial ownership of the legal entity. Bakkt's KYB proces is composed of three steps:
- Entity Account Registration (covered above)
- Upload of Entity and Owner Documentation
- Triggering of KYB Screen
Required Documentation
Clients are expected to upload all necessary documentation regarding business accounts and their respective owners to Bakkt in order to facilitate proper KYB screening. Details regarding how to upload documents can be found in the Uploading Documents section. In the event programmatic KYB is not viable for a given account, Clients will be provided a secure link to submit documentation. Clients must declare who the team can access the secure link.
Required documents:
- Certificate of Incorporation/Formation: This document is issued by the state or governing body when a company is legally registered, officially marking its formation. It typically includes the company’s name, date of incorporation, business structure, and sometimes information about initial directors. This certificate serves as proof that the business is legally recognized.
Bylaws/Articles of Association/Operating Agreements: These are foundational documents that outline the internal rules governing a business’s operations and management:- Bylaws apply mainly to corporations, detailing procedures for managing the company, such as board roles, voting rights, and meeting guidelines.
- Articles of Association are often required in certain countries for incorporated entities, specifying company regulations, shareholder rights, and director responsibilities.
- Operating Agreements are used by Limited Liability Companies (LLCs) to define ownership, management structure, and member responsibilities.
- Shareholder Registry is a formal document recording listing all shareholders or members of the company and detailing the number and class of shares held by each. It typically includes shareholder names, addresses, and the proportion of ownership, which can be essential for understanding control and financial interest in the company.
Organization Structure Chart Showing Beneficial Ownership: This visual chart maps out the company’s ownership structure, illustrating key individuals or entities who own, control, or influence the company.
- Beneficial Owner Documentation:
- Copy of Unexpired Passport or Driver’s License for all individuals with more than 25% interest.
- Copy of Unexpired Passport or Driver’s License for one individual with significant responsibility for managing the legal entity.
- Certificate of Beneficial Owners form.
Triggering a KYB Screen
Once a client has successfully uploaded all documentation to Bakkt for the entity and its respective owners, they must signal to Bakkt they are ready to screen the account. This will happen via the /apex-crypto/api/v2/accounts/triggerKYBScreening/{clientAccountId}
endpoint. Client's will need to specify the account ID in their request. Please note, if any of the owners on the entity account are entities themselves (businesses), the client must request a manual review for KYB. See the below section for more detail.
Manual KYB - Customer Information Form
If a client is not eligible for programmatic KYB screening (ex. one of their owners is also an entity), Bakkt will require that the client provide detailed information to comply with regulatory requirements manually. Clients should contact Bakkt Compliance or SRE via slack and should receive a form to fill out all necessary details:
-
Clients can open a business account as one of the following structures:Selecting a legal entity type.- Corporate
- Partnership
- Limited Liability Company
- Limited Partnership
- Trust
-
The form will collect the following information:Provide Business details- Customer Legal Name and Business Operating Address
- Primary Phone Number and Email Address
- Tax ID Number and Date of Formation
- Products and Services Offered related to cryptocurrency business activities
- Purpose of Digital Assets to be Acquired
- Anticipated Transaction Volume (monthly)
- Regulatory Body Registration details (if applicable)
- Net Worth (Total assets minus total liabilities)
- Initial and Ongoing Source of Funds to acquire crypto
- Countries of Business Operations
-
List the individuals authorized to act on behalf of customer:Identify Authorized Persons- For Corporations: List authorized Corporate Officers.
- For Partnerships: List all General Partners or Managing Members
- For Trusts: List all Trustees.
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Provide details for beneficial ownership:Certify Beneficial Ownership- Natural Person Acting on Behalf of Entity: Name and title.
- Beneficial Owners: List each individual who owns 25% or more of the equity interests.
- Individual with Significant Responsibility for Managing the Legal Entity: Provide relevant details such as name, title, current address, and ID number.
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Complete Certification and Signatures
- Certification by the natural person opening the account.
- Authorized signors for Corporations, Partnerships/LLCs, and Trusts must sign and date the form.
Manual Review
After all required information and documentation have been collected and verified, Bakkt’s compliance team will manually review the verification results. Bakkt will then notify the client once a decision is made. If approved, clients can access the Account Opening API to successfully enroll as a business; if rejected, the client will be informed of the reasons and any potential next steps.
Updated about 1 month ago