To satisfy regulatory obligations, every Organisation is required to identify all individuals who exercise significant control over the company during the ApprovalMax Pay Wallets onboarding process.
In ApprovalMax, these individuals are referred to as Business Owners and Directors, and their information is collected as part of the KYB checks in Step 3: Persons during onboarding.
Please note: This is a regulatory compliance requirement only and does not determine who can access ApprovalMax or manage payments.
Who is a Director?
A person who controls or manages the Organisation.
If your Organisation doesn't have a formal board of directors, we require information about those in equivalent roles, such as managing partners, managing members, or trustees.
Who is a Business Owner?
A real person (not a company) who directly or indirectly owns 10% or more of the Organisation.
This ownership can be held in their own name or through another company or structure.
Who is considered a Business Owner or Director for charities, trusts and not-for-profits?
For charities, trusts, and not-for-profits, trustees are treated as the Organisation’s controlling persons for KYB purposes.
This means all trustees are required to:
Provide basic personal details
Provide an email address for compliance checks
Who is considered a Business Owner or Director for Limited Liability Partnerships?
For LLPs, Persons with Significant Control (PSCs) are treated as Business Owners or Directors during onboarding.
A PSC is someone who:
Has more than 10% profit entitlement, or
Has more than 10% voting rights, or
Exercises significant influence or control over the LLP
Do all Business Owners and Directors need an ApprovalMax account?
No. There is a clear distinction between regulatory requirements and product usage.
No Invitations Sent: adding a PSC’s or trustee's email address is for compliance checks only. It does not automatically create an ApprovalMax account or send them an invitation via the application.
No System Interaction: trustees and PSCs do not need an ApprovalMax user account. They do not need to log in, approve payments, or interact with the system.
Operational Continuity: your existing operational users can continue to be the only people approving and making payments in ApprovalMax.
The Role of the Wallet Owner
While most members or trustees do not need accounts, every Organisation must nominate one individual as the Wallet Owner.
Identity Verification: the Wallet Owner must pass a verification check by providing an ID and a selfie with that ID.
Accountability: this person acts as the accountable individual for the Wallet.
System Access: the Wallet Owner is the only person who requires an ApprovalMax account in this context.
Flexibility: the Wallet Owner can be a Director, PSC, or trustee. They do not have to be a trustee unless your specific charity structure requires it.
Who actually uses ApprovalMax Pay Wallets?
Your existing operational users can remain the only people who:
Prepare payments
Approve payments
Manage day-to-day workflows
Providing information or completing KYB verification during onboarding does not change user access or approval permissions in ApprovalMax.