Summary of the due diligence process Green Check uses to ensure all partners meet or exceed our security and compliance requirements
Due Diligence Procedures
The initial due diligence process begins as soon as the prospective marketplace partner has signed our mutual non-disclosure agreement. It is imperative that the prospective partner understand that beginning the due diligence process is in no way meant to be construed as a promise that they will ultimately be featured in the marketplace.
Cadence of ongoing due diligence review is based on risk associated with business - i.e. higher risk vendors (payments, ATMs, Directs) would be done more frequently while others like insurance providers may be done on an annual basis. A due diligence review will also be triggered off cycle by significant events like a company acquisition, negative news, etc.
Initial Due Diligence
- GCV provides marketplace partner with due diligence questionnaire and due date
- Upon completion of the questionnaire, GCV reviews initial due diligence documentation and considers the following:
- What would we have to do to replace this service provider?
- What would that timeframe look like?
- What effect - if any - would it have on our customers?
- How would we manage the recovery of any of our data housed in their systems?
- Do we currently have other marketplace partners or vendors that provide these services? If so, what does this business offer that our partners or vendors don’t currently?
- Confirm business license(s) status
- Confirm business or associated persons do not appear on any US federal government watch lists
- Check for any negative news or other issues associated with the business or its principals
- Check customer reference
- Define our exit strategy:
- Determine risk rating for the business
- When appropriate, GCV's compliance team arranges a followup call with the partner due diligence contact to review results/findings
Ongoing Due Diligence
The cadence of ongoing due diligence is determined by the initial risk rating assigned to the partner during onboarding. Ongoing due diligence is conducted by requesting updated information about the partner and associated products/services. Additionally, GCV's compliance team will review the following:
- Confirm business license(s) validity (or) collect a copy of updated license(s)
- Confirm business or associated persons do not appear on any US federal government watch lists
- Check for any negative news associated with the business or its principals
- Check for any significant changes in business ownership (10% or more)
- Indicate any change in risk rating
- If risk is unacceptable, execute exit strategy
Document Resources
Green Check Due Diligence Questionnaire
Provided upon request. Please contact your account manager for a copy of this questionnaire
Due Diligence Research Resources
Office of Foreign Assets Control
OFAC Sanctions List Search
“Sanctions List Search is one tool offered to assist users in utilizing the SDN List and/or the various other sanctions lists; use of Sanctions List Search is not a substitute for undertaking appropriate due diligence.”
https://sanctionssearch.ofac.treas.gov/Default.aspx
Consumer Financial Protection Bureau
Consumer Complaint Database
“Only complaints sent to companies for response are eligible to be published and are only published after the company responds, confirming a commercial relationship or after 15 days, whichever comes first. The database generally updates daily. We do not publish complaints referred to other regulators, such as complaints about depository institutions with less than $10 billion in assets.”
https://www.consumerfinance.gov/data-research/consumer-complaints/
Better Business Bureau
Search Businesses and Charities
“Are you looking to find a BBB Accredited Business or see a business’s BBB rating? Do you want to see BBB reviews and complaints? To find what you are looking for, you can enter the type of business, business or charity name, keywords, phone number, website address, or email address in the search bar below.”
Company Website
Is there anything on the company website that suggests state-prohibited activity, ability to accept prohibited forms of payment, or is misaligned with what is provided on the due diligence form?
Google News
Negative News Search