KYC / Identity Verification

Neela — Identity Setup

I need to know what type of taxpayer you are — this determines which fields you'll fill out and whether we run individual ID (Persona) or business verification (Middesk KYB). The taxpayer who sells the relinquished property must be the same taxpayer who acquires the replacement — the IRS "same taxpayer" rule.

Who is the exchanger?

Individual — Identity fields

Legal First Name

Legal Last Name

SSN — last 4

Last 4 only — the full number is hashed at intake and never displayed

Date of Birth

Residential Address

Marital Status / Vesting

IRS "Same Taxpayer" Rule: The taxpayer/entity recorded here must be identical to the one on both the relinquished deed and the replacement purchase agreement. Open1031 validates this at every hub transition.

Neela — Persona Identity Check

You'll complete your identity check in the Persona window below. This takes about 2 minutes. Persona captures a photo of your government ID and a selfie — I'll extract and pre-fill the relevant fields once it completes. Your data is encrypted and never stored in plain text.

Persona Identity Verification

Secure biometric check powered by Persona. You'll photograph your driver's license or passport, then take a short selfie video.

Government-issued ID — front Captured

Government-issued ID — back In progress

Selfie video liveness check Pending

Position the back of your ID in frame

Persona result will be forwarded to QI review queue via kyc-orchestration

Neela — Document Review

I've extracted your name and DOB from the ID you captured. Please review the extracted values below and upload any additional supporting documents. I'll flag any discrepancies between the ID and your exchange profile.

AI-extracted from ID capture document-verification-merge

Full Legal Name Matthew J. Belcher Neela extracted · matches profile

Date of Birth ••/••/1978 Neela extracted · matches profile

ID Expiry Sep 2028 Valid — not expired

Required documents

Government-Issued Photo ID — Front

CA Driver License — captured via Persona

Verified

Government-Issued Photo ID — Back

CA Driver License — captured via Persona

Verified

Selfie — Liveness Check

Short video selfie for biometric matching

Proof of Address (optional)

Utility bill or bank statement, dated within 90 days

Neela — OFAC SDN Screening

The OFAC SDN check is required by BSA/AML law before any exchange can proceed. I ran the screening automatically using your verified name and DOB. The result is shown below. This screening is point-in-time — it runs once, here, at the moment you are added. No rescreening cadence is set: a periodic re-run of ofac-sdn-screening is designed but not scheduled, so a later change to your profile is not screened again on its own.

OFAC SDN — Clear No match

No match found against the U.S. Treasury OFAC Specially Designated Nationals (SDN) list. Screening performed against full legal name "Matthew J. Belcher" and DOB ••/••/1978.

Screened Jun 1, 2026, 14:32 UTC

ofac-sdn-screening Report ID: SDN-2026-06-1087

Screening details

Name screened Matthew J. Belcher

Screening list OFAC SDN + Consolidated Sanctions

Match score 0.00 — no match

Next auto-rescan None scheduled — screening is point-in-time

Report ID: SDN-2026-06-1087

Neela — Awaiting QI Sign-Off

Your identity documents and OFAC screening are complete. Per our QI procedures, Priya Anand must review your Persona KYC report before your exchange is activated. This is a compliance requirement — not a delay. Most reviews complete within 4 business hours.

QI Review — Priya Anand

Qualified Intermediary Officer · Open1031

Under Review

Persona KYC report received Complete

OFAC SDN screening — clear Clear

Identity documents uploaded 2 of 2

QI manual review of Persona report Awaiting QI

Exchange activation Locked

Estimated review time: 2–4 business hours kyc-orchestration

What happens next

You'll receive an email at matt@example.com when Tom approves or if additional information is needed.

Once cleared, your exchange will activate automatically. Your 45-day identification clock starts on the day you transfer the relinquished property — your closing date — not when funds arrive in escrow (Treas. Reg. §1.1031(k)-1(b)(2)).

The QI Engagement Letter will be sent via DocuSign for your signature — a separate step from identity verification.

Identity Verified — Exchange Activated

Priya Anand has cleared your KYC review. Exchange #1087 is now active. Your 45-day identification window begins on the day you transfer the relinquished property — your closing date — not when sale proceeds arrive in your segregated QI escrow account.

Exchange #1087

Exchanger Matt Belcher

KYC Status Cleared

OFAC Status Clear

Cleared by Priya Anand (QI)

Cleared at Jun 1, 2026 · 16:14 UTC

Automation status for Exchange #1087 2 of 4 not yet armed

Funds receipt in escrow — recorded by a QI officer, not detected escrow-funds-received · not yet armed

45-day countdown — anchored on the relinquished-property closing, recorded when a QI officer logs escrow receipt; no reminder is sent forty-five-day-id-watcher · not yet armed

QI Engagement Letter sent to DocuSign qi-engagement-generate · done

Dashboard KPIs updated dashboard-kpi-update · done

Loading identity verification status from kyc-orchestration

Neela — KYB Entity Verification (Middesk)

For an LLC exchanger, we run KYB (Know Your Business) through Middesk — checking your entity against the Secretary of State registry and verifying beneficial owners. Each UBO with ≥ 25% ownership also needs individual IDV. I'll walk you through collecting those details.

Business Entity Details

kyc-orchestration · Middesk

Legal Entity Name

EIN / Tax ID

Formation State

Entity Type

Authorized Signatory

Beneficial Owners (UBOs) — FinCEN Rule

All individuals owning 25% or more of the entity must complete individual KYC. Each UBO's identity is verified separately via Persona.

Matthew J. Belcher

100% ownership · Authorized signatory

IDV Pending

Middesk SOS Registry Check Pending submission

Once you submit the entity details above, Middesk will verify "Belcher Real Estate Holdings LLC" against the California Secretary of State registry. This usually resolves in under 5 minutes.

kyc-orchestration via ADR-011 Middesk integration

Build contract — identity verification

1 · KYC is the first gate, and it can only be cleared by the person being verified plus a QI officer. No coordinator, co-exchanger or admin may mark this exchanger verified on their behalf. The Persona result and the OFAC disposition are the only things that move the state — the UI never sets it.
2 · An OFAC hit is a hard block, not a warning. While a potential SDN match is open, no exchange funds may be deposited, disbursed or transferred. There is no override control on this surface and none may be added; clearing a match is a documented QI disposition recorded through ofac-sdn-screening, with the reviewer, timestamp and rationale written to the audit log.
3 · The platform never holds a full SSN to show. Sensitive identity fields live in profiles_sensitive; the SSN is stored as last-4 plus a hash. The field above is therefore display-only with no reveal affordance — building one would imply a capability that does not exist and must not.
4 · Machine-extracted values are labelled as such. Anything Neela pulled off a captured ID carries its provenance and stays reviewable until a human confirms it. Extraction is never rendered as verification.
5 · Every step is a durable workflow step. The stepper mirrors kyc-orchestration — it does not simulate it. Each transition writes an audit-log entry, and a stalled step surfaces in the QI queue rather than silently waiting.
6 · The entity path is a different legal object. Selecting LLC, partnership, corporation or trust routes to KYB with UBO collection at the 25% FinCEN threshold, and each UBO completes their own individual IDV. The same-taxpayer rule is validated at every hub transition, not asserted once here.
7 · Tokens only. No raw hex in the implementation. Every colour resolves through tokens.css; text on a filled control uses that control's -on token (--hub-on) because white fails AA on the dark-theme fills. --ink-4 is icons, rules and disabled glyphs only — never body text.
Light and dark are both designed here. Every name, date, address and identifier on this surface is synthetic demo data.