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_supportability_inquiry or other_compliance_inquiry requirements. Risk verification requirements follow the <id>.<requirement_description>.<resolution_path> format.

This update adds the:

• external_hold error code to the requirements.errors array in the Accounts API.
• notice resolution path to risk verification requirements.

This update also adds the following new descriptions to risk verification requirements:

• legal_hold: We must hold funds for legal reasons. Fulfilling the requirement can involve remitting funds to a third party.
• pep_review: We need to verify that the business isn’t involved with a person of interest or a politically exposed person.
• sanctions_review: We need to verify that the business isn’t involved with a sanctioned person or jurisdiction.

Requirements with a description of sanctions_review or pep_review show up in pending_verification 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_supportability_inquiry requirement description.

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.

Changes

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