Investors
Investors are natural or legal persons that buy and hold units of a digital security.
Creating an investor
Investors can be created via the investor endpoints. The information stored with an investor includes the following mandatory data:
personal data
residence address
In addition, the following data can be optionally stored for the investor if needed:
bank account
securities deposit account
tax information
Depending on the product's configuration, investors need to have this data set.
Account setup document
Via the investor endpoint, you're required to deliver the date and time on which the investor agreed to a set of account setup documents. The documents are signed and marked with the investor data after the KYC/AML process for that investor is completed. After that, you are able to retrieve the signed documents via the signed documents endpoint for that investor.
Your contact at Cashlink will provide you with the set of account setup documents that your investors need to confirm.
This is only required if you use the Investment Platform API offering. If you use the Registry-as-a-Service API product, adding this to the investor is not required.
Creating legal persons
You can also create an investor that is a legal person. In this case, you need to provide additional information. For the account setup to be successful you'll need to add company data such as the company name and documents proofing the identity of the company.
Benefiting persons
If you have created a legal person as an investor, you also need to provide the data of the benefiting persons of the legal person via the benefiting persons endpoint.
If you have created an investment for that legal person, the status of the investment will remain in the KYC_PENDING step until you provide the data of at least a single benefiting person.
Please make sure that you're only onboarding investors where the benefiting persons are not "politically exposed persons" (PEP). During the KYC/AML process a background check is performed and investments of PEPs may be rejected.
If the benefiting persons change, please add the new persons via a new POST request. You don't need to delete already added benefiting persons if they're not a benefiting person any more.
Identifications
Investors need valid identification data that is the result of a video identification process. In order to get this data, you need to follow this process:
Via the identification endpoints, create a new identification with an empty JSON request. The API will return a URL to the identity provider and the ID of the identification process.
Redirect the investor to the provided URL. The investor can use that URL to finish the video identification process.
You can use the identification endpoints and the identification ID to query the current status of the identification.
After the identification is finished, the result data is available via the same API call.
You don't need to add the identification data during the creation of the investor or even before an investment is created. However, for investments to succeed, a valid identification must be set. Otherwise, investments will stay in the KYC_PENDING status.
Wallets
In order to receive digital securities during the settlement process, investors need wallets. Wallets are created for investors using the wallet endpoints.
You can create an investment for an investor without a wallet present. However, at the time you want to credit the purchased digital securities, a wallet needs to be set.
There are two different types of wallets:
Generic wallets are created via the /eth-generic/ endpoint by providing an account address. An account address is always connected to a single investor identity. It cannot be shared between investors. An investor can have more than one generic wallet.
Managed wallets are created via the /eth-managed/ endpoint. You don't need to provide an address for managed wallets because the address is created when you trigger the creation via the API. Investors can only have a single managed wallet. Managed wallets are provided by Tangany. This needs to be setup for your platform and investors need to accept the Tangany custody terms and conditions before you create a wallet via the API.
Please note that in order to create a wallet, the investor must have completed the KYC/AML process.
Knowledge and experiences survey
In order for investors to make an investment a check of the knowledge and experiences of the investor is mandatory. This is intended to protect investors from making uninformed investment decisions that can result in a loss of a substantial amount of their capital. This requirement is set up in relation to § 63 sec. (5) WpHG.
Investors must therefore answer a questionnaire about their knowledge and experience with investing.
The questionnaire contains three groups of questions:
Group 1: Experience with investment products
The questions and answers have the following keys:
Key |
investmentexperience_investment_fund |
investmentexperience_money_market_funds |
investmentexperience_bond |
investmentexperience_share |
investmentexperience_participation_right |
investmentexperience_participation_paper |
investmentexperience_operative_participation_in_a_limited_partnership |
investmentexperience_contract_for_difference |
investmentexperience_crypto_currency |
investmentexperience_unsecured_junior_debt |
investmentexperience_certificate |
investmentexperience_warrants |
investmentexperience_alternative_investment_fund |
Valid answers for all of these questions are the following:
Key |
no_answer |
zero_to_three_years |
three_to_five_years |
greater_than_five_years |
Group 2: Knowledge with investment products
In addition to the experience you also have to ask the investor about the knowledge they have with the different investment types. The following keys can be used for this:
Key |
investmentknowledge_investment_fund |
investmentknowledge_money_market_funds |
investmentknowledge_bond |
investmentknowledge_share |
investmentknowledge_participation_right |
investmentknowledge_participation_paper |
investmentknowledge_operative_participation_in_a_limited_partnership |
investmentknowledge_contract_for_difference |
investmentknowledge_crypto_currency |
investmentknowledge_unsecured_junior_debt |
investmentknowledge_certificate |
investmentknowledge_warrants |
investmentknowledge_alternative_investment_fund |
Valid keys for the answers are the following:
Key |
no_answer |
no_knowledge |
knowledge |
Group 3: Service experience
It's mandatory to add the following keys to the questionnaire:
Key |
serviceexperience_independent |
serviceexperience_investment_consultancy |
serviceexperience_investment_management |
Valid answers for this group are the following:
Key |
no_answer |
no_knowledge_or_experience |
zero_to_three_years |
three_to_five_years |
greater_than_five_years |
Group 4: Past investments
It's also mandatory to ask the following two questions about the past investments of the investor.
The first question has the key avgyearlytransactions. Valid answers for this question are the following:
Key |
no_answer |
no_trans |
lower_5_trans |
lower_10_trans |
more_than_10_trans |
The second question has the key avgtransactionvalue. Valid answers for this question are the following:
Key |
no_answer |
lower_3000 |
between_3000_and_5000 |
between_5000_and_10000 |
over_10000 |
You may not need to show all questions to your investors. The precise set of questions you need to ask is set during the platform onboarding.
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