Adds specific descriptions for risk requirements during legal, PEP, and sanctions reviewBreaking changes
What’s new
Adds two new requirements, resolution paths, and a new error code for risk requirements related to legal holds, PEP reviews, and sanctions reviews. These were previously categorized as other_ or other_ requirements. Risk verification requirements follow the <id>. format.
This update adds the:
external_error code to thehold requirements.array in the Accounts API.errors noticeresolution path to risk verification requirements.
This update also adds the following new descriptions to risk verification requirements:
legal_: We must hold funds for legal reasons. Fulfilling the requirement can involve remitting funds to a third party.hold pep_: We need to verify that the business isn’t involved with a person of interest or a politically exposed person.review sanctions_: We need to verify that the business isn’t involved with a sanctioned person or jurisdiction.review
Requirements with a description of sanctions_ or pep_ show up in pending_ to indicate that the requirement is pending review by Stripe and doesn’t require any user action to resolve.
Why is this a breaking change?
This change will break existing integrations that aren’t updated to explicitly handle these new requirements. Sanctions, PEP review, and legal hold requirements were previously represented by the less-specific other_ requirement description.
| Requirement | Previous API requirement | New API requirement |
|---|---|---|
| Account under sanctions review | interv_ | interv_ |
| Account under PEP review | interv_ | interv_ |
Account has a legal hold with additional information in the associated external_ error | interv_ | interv_ |
| Account has a legal hold without additional information | interv_ | interv_ |
The following example shows a truncated response from the v1/accounts API for an account with payouts disabled due to a legal hold
{ "id": "acct_123", // ... "requirements": { "alternatives": [], "current_deadline": null, "currently_due": [ "interv_def789.legal_hold.notice" ], "disabled_reason": "requirements.past_due", "errors": [{ "requirement": "interv_def456.legal_hold.notice", "code": "external_request", "reason": "There is an active levy on this account. Ask the account to have the government agency, Llama Revenue Services, send a signed release to llg-notices@stripe.com." }], "eventually_due": [ "interv_def789.legal_hold.notice" ], "past_due": [ "interv_def789.legal_hold.notice" ], "pending_verification": [] }, "payouts_enabled": false, // ... }
This example shows a truncated response from the Accounts v1 API for an account that has payouts disabled due to both a pending sanctions and a pending PEP review
{ "id": "acct_456", // ... "requirements": { "alternatives": [], "current_deadline": null, "currently_due": [], "disabled_reason": "requirements.pending_verification", "errors": [], "eventually_due": [], "past_due": [], "pending_verification": [ "interv_def123.sanctions_review.support", "interv_def456.pep_review.support", ] }, "payouts_enabled": false, // ... }
Impact
You will gain a better understanding of capability limitations caused by sanctions reviews, PEP reviews, and legal holds and whether any action is required from you to resolve the requirement.