1. Description
This Dynamic Account Opening service enables TPPs to initiate Account Opening Service Requests to a number of LFIs, providing them with necessary Users' data required for initiating account their opening and onboarding process for new Users. In the context of the Open Finance FX & Remittance Services, this refers to Users who received and selected a quote from a specific LFI for their FX & Remittance requirements and they do not have an existing account with the LFI. This service enables Users to respond to the FX Services quote by selecting to open a new account with the LFI in order to proceed with actioning the quote. However, please note that the Account Opening service initiation does not need to be of an FX Services quote, but can be offered to Users by TPPs as a standalone service.
As part of the account opening service request, Users may provide TPPs with their consent to access their existing account(s) with other LFIs, in order to acquire the Users personal data, that can be used to populate the account opening service requests to be sent to the LFIs. The Users' consent to TPPs for Data Sharing requests of existing personal data for the purpose of account opening MUST be a short-lived consent (i.e. lasting for 24 hours max). During this period, TPPs will be making a number of Data Sharing requests to acquire all the personal data necessary for the account opening initiation.
For the Account Opening service initiation Users do not need to provide explicit consent to TPPs for initiating the process with LFIs.
The above functionality will enable the participation of Exchange Houses in the Open Finance program and promote a more competitive market environment where Users can benefit from the best FX services deals available.
The Account Opening service initiation will be based on the dataset available from the Data Sharing functionality and may be subject to additional asynchronous processes by each participarting LFI.
Note
A. The Account Opening service initiation capability is optional for LFIs. LFIs are not currently mandated to implement it, but they are able to do so on a voluntary basis for commercial, competitive or other reasons deemed necessary.
B. The Account Opening service initiation process of LFIs MUST be in compliance with the Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and also Know Your Customer (KYC) protocols.
1.1 Customer Segments Scope
The scope of the IP Payments bank service initiation related to the segments of Debtors and Creditors is shown below:
Consumers | SME | Corporates |
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1.2 Example User Story - Dynamic Account Opening with LFIs (UC-5)
As a User (Consumer or SME Business),
I want to provide a TPP with all the necessary personal customer and other related information from my current LFI and share this information with an LFI of my choice requesting the opening of a new account,
so that I can easily get a new account and onboard with the LFI and be able to use their FX services.
1.3.Process flow
The below diagram depicts the high level process flow for the dynamic account opening and onboarding service:
2. User Journey
2.1 Account Opening Basic Journey
2.2 Share Personal Data (Conditional)
As defined in https://openfinanceuae.atlassian.net/wiki/spaces/standardsv2draft2/pages/304550037/Customer+Data#2.-User-Journey
3. Customer Experience
TBC
3.1 Rules & Guidelines
# | Step | Rules & Guidelines |
|---|---|---|
BNK-AC-REQ-1 | Identify LFI for Account Opening | TPPs MUST: 1.1 Provide Users with the list of available LFIs available for dynamic account opening and allow Users to select the LFI they want to open a new account with.
1.2 Use the name of the LFI selected by the User based on the received FX services quote, if this journey is a continuation of the https://openfinanceuae.atlassian.net/wiki/x/UwB2Eg journey. |
BNK-AC-REQ-2 | Data Sharing Consent for Account Initiation Purposes (Conditional) | TPPs MUST: 2.1 Enable Users to provide the name of one of their existing LFIs which can be used to provide the User’s Customers personal data required for generating the Account Opening service initiation requests. 2.2 Request Users to provide their explicit consent to TPPs to receive their customer personal data required for dynamic account opening from their existing account holding LFIs.
2.3 Enable Users to proceed with the Data Sharing customer journey as per the user journey https://openfinanceuae.atlassian.net/wiki/spaces/standardsv2draft2/pages/304550037/Customer+Data#3.-Customer-Experience and the requirements defined in https://openfinanceuae.atlassian.net/wiki/spaces/standardsv2draft2/pages/304550037/Customer+Data#3.1-Rules-%26-Guidelines . |
BNK-AC-REQ-3 | Data Sharing Requests for Account Initiation Purposes (Conditional | TPPs MUST: 3.1 Use the data sharing consent to request and retrieve Users' s customer personal data for dynamic account opening purposes as per the requirements defined in https://openfinanceuae.atlassian.net/wiki/spaces/standardsv2draft2/pages/304550037/Customer+Data#3.1-Rules-%26-Guidelines. |
BNK-AC-REQ-4 | Manual Data Entry for Account Initiation Purposes (Conditional) | TPPs MUST: 4.1 Request Users to manually provide the data required for the Account Opening service initiation requests in the following cases:
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BNK-AC-REQ-5 | Data Review/Edit & User Confirmation | TPPs MUST: 5.1 Allow Users to review the data collected by the TPP that will be used in the Account Opening service initiation requests to the selected LFIs. 5.2 Enable Users to edit the data elements they wish in order to manually correct erroneous data and other data inconsistencies. 5.3 Enable Users to confirm that they are happy to proceed to the Account Opening initiation process, using the data presented by the TPPs. 5.4 Include in the Account Opening service request, the following additional information about each field of the Users' customer personal data:
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BNK-AC-REQ-6 | Account Opening Initiation Requests | TPPs MUST: 6.1 Initiate the Account Opening service initiation requests to the selected LFIs using the Open Finance Platform (OFP). 6.2 Submit to OFP the Account Opening service initiation requests with the Users' customer personal data they received using the data sharing functionality, or provided by Users manually. All data MUST have been confirmed by Users. 6.3 Each Account Opening service initiation request will contain the information as stated in https://openfinanceuae.atlassian.net/wiki/spaces/standardsv2draft2/pages/309788673/Dynamic+Account+Opening#4.1-Account-Opening-Service-Initiation-Data. 6.4 Be able, as part of the Account Opening service initiation requests, to register a callback API endpoint (i.e. webhook). This will be used by the LFI to asynchronously notify the OFP and the TPP that the new user account has been opened with the LFI as per the service initiation request. |
OFP MUST: 6.5 Allow the TPPs to submit each individual Account Opening service initiation request without any additional MFA or authorization from the User. 6.6 Forward the Account Opening service initiation request to the selected LFI together with the users' customer personal data required for the new account opening process. | ||
BNK-AC-REQ-7 | Account Opening Staging | LFIs MUST: 7.1 Be able to receive the Account Opening service initiation requests and use the provided Users' customer personal data to initiate their account opening process in near-real-time (and not-real-time in certain scenarios). 7.2 Respond to the Account Opening service initiation requests by sending their response messages back to the OFP. 7.3 Include in the Account Opening service initiation responses the redirection information that TPP MUST use for redirecting Users to the LFIs. |
OFP MUST 7.4 Forward the Account Opening service initiation responses back to the initiating TPPs. | ||
BNK-AC-REQ-8 | Hand-off to LFI | TPPs MUST: 8.1 Provide messaging to inform Users that they will be redirected to the LFIs to complete the account opening process.
8.2 Redirect the Users to the LFIs' web interface or the LFIs' app if available (download maybe required first) in order to continue with the he account opening process. |
LFIs MUST: 8.3 NOT present any additional inbound redirection screens. 8.4 Request the details included in the staged Account Opening resource from the OFP | ||
OFP MUST: 8.5 Provide the Account Opening details to the LFIs based on the unique Account Opening resource identifier. | ||
LFIs MUST: 8.6 Initiate the Account Opening and Onboarding process. | ||
BNK-AC-REQ-9 | Account Opening process | LFIs MUST: 9.1 Present to Users a user registration page (for web) or screen (for app) which will contain the Users' customer personal data received by the TPP as part of the Account Opening service initiation request. 9.2 Request Users to review and confirm their details are correct.
9.3 Verify the Users' provided contact details including mobile phone number and email address. 9.4 Request Users to provide electronic copies of their User identity information such as the Emirates ID or passport. This may be by taking photos of an existing paper document or uploading an electronic version of the document. This may be required if these have not already been included in the data provided by the Account Opening service initiation request. 9.5 Request users to provide biometric details that can be matched against the provided identity documents. The most common biometrics used is facial biometrics using a photo or video for facial recognition and matching against the Emirates ID or passport. 9.6 Request Users to provide the following additional information:
9.7 Request Users to Accept T&Cs and provide their final confirmation for the Opening of the Account. 9.8 Advise Users about the timelines for the completion of the Account Opening process. |
BNK-AC-REQ-10 | Hand-off back to the TPP | LFIs MUST: 10.1 Confirm to the OFP that the interaction session is now completed. |
OFP MUST: 10.2 Initiate the User Redirection process by providing all necessary information to the LFI. | ||
LFIs MUST: 10.3 Provide messaging to inform Users that they will be taken back to their TPP. 10.4 4 Redirect Users to the TPP immediately after receiving the required information from the OFP. | ||
BNK-AC-REQ-11 | Account Opening Status Update | LFIs MUST: 11.1 Set the status of the New Account resource to “Opened” 11.2 Send an Account Open Confirmation notification to the OFP using the registered callback API endpoint (i.e. webhook). .11.3 Include in the Account Open Confirmation notifications the information as per https://openfinanceuae.atlassian.net/wiki/spaces/standardsv2draft2/pages/309788673/Dynamic+Account+Opening#4.2-Account-Open-Confirmation-Data. |
OFP MUST: 11.3 Forward the Account Open Confirmation notifications to the TPP including all the information provided by the LFIs. | ||
BNK-AC-REQ-12 | Confirmation to User | TPPs MUST: 12.1 Confirm to Users the outcome of their Account Opening service initiation request with the LFI.
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BNK-AC-REQ-13 | User Notifications | TPPs MUST: 13.1 Send a notification about the outcome of the Account Opening service initiation request to Users, if they are not present at the TPP app. LFIs MUST: 13.2 Send a notification to Users on the success or failure of the Account Opening service initiation request. 13.3 Use SMS as a minimum channel to notify Users and optionally any other allowable channels (e.g. email, app notifications) currently used for account opening related notifications to their customers depending on UAE rules and regulations, for all Open Finance related notifications to Users. 13.4 Use the Users' verified contact details to inform them about the credentials of accessing the new account account. 13.5 Identify in the notifications the TPP initiating the the Account Opening service request. |
5.3.2 Requirements (WIP)
ID | Requirement |
|---|---|
BNK-FXAC-REQ-1 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to dynamically open accounts and onboard new users in compliance with the Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and also Know Your Customer (KYC) protocols. |
BNK-FXAC-REQ-2 | The Open Finance Enhanced FX solution(s) MUST enable Users, before the FX account opening, to provide TPPs with the name of one of their existing LFI or FX Houses which can be used to provide User’s Customers personal data required for generating a new FX account open request with their selected FX House. |
BNK-FXAC-REQ-2 | The Open Finance Enhanced FX solution(s) MUST allow Users to provide their explicit consent to the TPP to receive their user Customer personal data for the purpose of FX account opening from their existing LFI or FX House. |
BNK-FXAC-REQ-3 | The Open Finance Enhanced FX solution(s) MUST clearly identify that the purpose of the data sharing consent is for new FX account open service request. Moreover, the consent SHOULD include the the FX House that will receive the users' data for FX account opening purposes. |
BNK-FXAC-REQ-4 | The Open Finance Enhanced FX solution(s) MUST only allow TPPs to use a data sharing consent with the Customer Data related clusters for the purpose of account opening. Moreover, the consent duration for this purpose MUST be short-lived (24 hours period or less) |
BNK-FXAC-REQ-5 | The Open Finance Enhanced FX solution(s) MUST enable the data sharing process for FX account opening purposes to proceed as per the requirements defined in https://openfinanceuae.atlassian.net/wiki/spaces/Internal/pages/247627777/Open+Finance+Enhanced+FX+Proposition#5.1-Data-sharing-for-FX-%26-Remittances-Services. |
BNK-FXAC-REQ-6 | The Open Finance Enhanced FX solution(s) MUST allow TPPs to request from the Users to manually provide the Customer data required in the FX account opening data set which have not been provided by the data sharing activity. Additionally, they MUST enable TPPs to allow Users to modify the data, if they think appropriate (e.g. to correct erroneous data provided). |
BNK-FXAC-REQ-7 | The Open Finance Enhanced FX solution(s) MUST allow TPPs to include in the FX account opening service request, the following additional information about each field of the Users' Customer personal data:
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BNK-FXAC-REQ-8 | The Open Finance Enhanced FX solution(s) MUST allow TPPs to initiate the FX account opening service requests to the selected FX House using the API Hub. TPPs will include in the service requests all the Users' Customer personal data they received using the data sharing functionality, or provided by Users manually. The API HUB will be forwarding the service requests to the FX House together with the users' Customer personal data required for the FX account opening service requests. |
BNK-FXAC-REQ-9 | The Open Finance Enhanced FX solution(s) MUST allow TPPs to include in their FX account opening service requests, the following information: Individual Customers (Personal Accounts) A. Personal Information, including:
B. Identification Documents, including:
C. Proof of Address, including:
D. Financial and Banking Details, including:
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BNK-FXAC-REQ-10 | The Open Finance Enhanced FX solution(s) MUST allow TPPs as part of the FX account opening service requests to register a callback API endpoint (i.e. webhook). This will be used by the FX House to asynchronously notify the API HUB and the TPP that the new User FX account has been opened with the FX House as per the request. FX House MUST also include the relevant information for the new FX account. |
BNK-FXAC-REQ-11 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to receive the FX account opening service requests and use the provided Users' Customer personal data to execute their FX account opening process in near-real-time (and not-real-time in certain scenarios). |
BNK-FXAC-REQ-12 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses, to respond to the FX account opening service requests by sending with their response messages back to the API Hub. Moreover, the Open Finance Enhanced FX solution(s) MUST allow the API Hub to forward the account opening service request responses back to the initiating TPPs. |
BNK-FXAC-REQ-13 | The Open Finance Enhanced FX solution(s) MUST enable TPPs to redirect the users to the FX House’s web interface or to the FX House’s app if available (download maybe required first). |
BNK-FXAC-REQ-14 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to present to Users a user registration page (for web) or screen (for app) which will contain the Users' Customer personal data received by the TPP as part of the FX account opening service request. Users MUST review and confirm their details are correct. |
BNK-FXAC-REQ-15 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to request Users to manually provide any information required for the FX account opening which is missing from the Customer personal data received by the TPP as part of the FX account opening service request. Users MUST review and confirm their details are correct. |
BNK-FXAC-REQ-16 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to verify the Users' provided contact details including mobile phone number and email address. |
BNK-FXAC-REQ-17 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to request Users to provide electronic copies of their User identity information such as the Emirates ID or passport. This could be achieved by taking photos of an existing paper document or uploading an electronic version of the document. |
BNK-FXAC-REQ-18 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to request users to provide biometric details that can be matched against the provided identity documents. The most common biometrics used is facial biometrics using a photo or video for facial recognition and matching against the Emirates ID or passport. |
BNK-FXAC-REQ-19 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to request Users to provide the following information: A. Financial and Banking Details, including:
B. Compliance & Declaration Forms
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BNK-FXAC-REQ-20 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to send an FX Account Open Confirmation notification to the API HUB and the originating TPP using the registered callback API endpoint (i.e. webhook). |
BNK-FXAC-REQ-21 | The Open Finance Enhanced FX solution(s) MUST enable FX Houses to include in the FX Account Open Confirmation, the following information:
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BNK-FXAC-REQ-22 | The Open Finance Enhanced FX solution(s) MUST enable Users to get confirmation of their new FX account open by both the originating TPP and the account holding FX House. The FX House MUST use the Users verify contact details to inform them about the credentials of accessing the account. |
3.4 Journey Variations
4. Dynamic Account Opening Common Rules & Guidelines
4.1 Account Opening Service Initiation Data
TTPs MUST:
4.1.1 Include the following information in each Account Opening service initiation request:
Individual Customers (Personal Accounts)
4.1.1.1 Personal Information, including:
Full Name (as per Emirates ID or Passport), Nationality, Date of Birth
Residential Address (proof may be required) Contact Details (mobile number and email)
Employment Details (job title, employer name, or business details if self-employed), Tax Identification Number (TIN) (if applicable)
4.1.1.2 Identification Documents, including:
Emirates ID (for UAE residents) – both front and back copies,
Passport Copy (for non-residents or expatriates),
Valid UAE Visa Copy (for expatriates)
4.1.1.3 Proof of Address, including:
Recent Utility Bill (DEWA, Etisalat, Du, etc.),
Tenancy Contract or Ejari Certificate (if requested),
Bank Statement (with UAE address, dated within the last 3 months)
4.1.1.4 Financial and Banking Details, including:
Bank Account Details (for deposits and withdrawals)
4.1.2 Include the following additional information in each Account Opening service initiation request, if the Account Opening service initiation is a continuation of the https://openfinanceuae.atlassian.net/wiki/x/UwB2Eg journey:
FX Services Quote Reference Number: A unique quote identification for tracking purposes
4.2 Account Open Confirmation Data
TTPs MUST:
4.2.1 Include the following information in the Account Open Confirmation messages:
FX Account identification details (e.g. account number/ID or IBAN)
Account Features & Services, including:
Currency Pairs Available: List of supported currencies for exchange.
Transaction Methods: Bank transfers, cash transactions, online trading, etc.
FX Products: Spot exchange, forwards, options, remittances, etc.
Multi-Currency Support: If the account can hold multiple currencies.
8. Considerations
8.1 Constraints
FX Houses must only allow data sharing or FX & Remittance services initiation after authenticating Users using multi-factor authentication (MFA), as the Strong Customer Authentication Guidelines.
The API Hub does not have the capability of broadcasting a single API message to multiple recipients. Therefore, TPPs must generate multiple FX & Remittance quote API requests, one for each FX House (or LFI) that is required to generate a quote based on the Users' preferences. The quote request API messages sent to each FX House (or LFI) will be the same for all insurrer FX Houses (or LFIs).
FX houses are regulated by the Central Bank of the UAE (CBUAE), which defines their scope of operations. Their licenses typically do not permit trading in speculative or derivative financial products like futures contracts. Futures contracts fall under the jurisdiction of the Securities and Commodities Authority (SCA), which oversees brokers and financial institutions that provide derivative trading. FX Houses are designed to provide straightforward, practical financial services, such as currency exchange and remittances. Offering futures contracts requires specialized infrastructure, trading platforms, and expertise, which are outside their operational focus. The typical customers of FX Houses, consumers and SMEs, are more likely to need currency conversion or cross-border payments rather than complex trading instruments.
8.2 Dependencies
The FX Houses are able to provide real-time quotations of FX & Remittance services based a specific data provided to them by TPPs.
The FX Houses are able to lock a specific FX conversion rate as part of the quote, for a period of time long enough to allow TPPs to initiate the FX & Remittance services based on the values defined in the quote.
The connectivity between TPPs and FX Houses, for the Open Finance Enhanced FX functionality in scope will be taking place via the API Hub.
The ability for fast online account opening and onboarding of new users by FX Houses, partially depends on the quality of the data provided by the User and/or their existing FX House or LFI.
The FX Houses are able to support digital online account opening and onboarding based on the data provided to the them by TPPs and/or the Users in automated process and within certain timelines that may need to be defined by the Open Finance Standard.
8.3 Assumptions
It is expected that FX Houses will be able to provide the same data as LFIs for the Customer data and Transactions permissions as currently implemented by LFIs.
For data sharing functionality, FX Houses are subject to the same data retention period as required by LFIs.
For data sharing functionality, the maximum consent validity period will be 12 months in alignment with the Banking LFIs.
For quotation functionality, it is assumed that all FX Houses will require the same data set for providing an FX & Remittance quote, subject to the service requested.
For data opening functionality, it is assumed that all FX Houses will require the same data set for proceeding with the the dynamic account opening and onboarding. This set will be the superset of all the data requirements identified in the FX Houses market.
The API Hub will not be storing any users' Customer personal data or users' quotation data, instead data will only be transferred by the sharing insurer FX Houses (or LFIs) to the TPPs.
The FX Houses will be able to use the Centralized Authentication and Authorization process offered by the Open Finance Platform, as defined in Centralized Authentication and Authorization.
The FX Houses will be responding with quotes to all requests for FX & Remittance quotes, subject to supporting the services in their own channels (e.g. specific currency pairs or inability to perform certain money transfers).