Dwolla defines Elevated Security Merchants to include any customer that:

  • Engages in the sale, purchase, trade, or exchange of currency or currency equivalents
  • Any customers whose account activity results in 1% or greater returns than the sum of their monthly transaction volume

Due to federal regulations, Dwolla must ensure that all Virtual Currency Exchanges or accounts participating in the trade of virtual currency are registered with the Financial Crimes Enforcement Network (FinCEN).  You can view the regulatory guidance: FIN-2013-G001.

Your firm must provide us with your registration documents and you must maintain your status with FinCEN to continue utilizing Dwolla’s services.

Further, we require that all “currency equivalents” have a customer identification program established, documented and approved by Dwolla prior to the use of the service.

Specifically, the following data elements are to be collected and verified for each account that may qualify as an elevated security merchant:
  1. First and Last Name
  2. Present Residential Address
  3. Date of Birth
  4. Social Security Number
  5. State issued identification or passport

If you believe your business meets this criteria, please contact compliance@dwolla.com with the following:
  • What service or internal process allows you to validate items 1-4? (e.g. TransUnion, VeriSign, etc.)
  • What service(s) or internal process(s) allows you to validate item 5? (e.g.Lexis Nexis/ Idology, etc.)

For additional details on Dwolla’s requirements, please review our Terms of Service.

How do I send money to an elevated security merchant?
In order to send money to an Elevated Security Merchant, your account and identity must be validated with knowledge-based assessment questions. In some cases, Dwolla may ask you to present photo identification for validation.

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Financial institutions play an important role in the Dwolla network.

Dwolla, Inc. is an agent of Veridian Credit Union and Compass Bank and all funds associated with your account in the Dwolla network are held in pooled accounts at Veridian Credit Union and Compass Bank. These funds are not eligible for individual insurance, including FDIC insurance and may not be eligible for share insurance by the National Credit Union Share Insurance Fund. Dwolla, Inc. is the operator of a software platform that communicates user instructions for funds transfers to Veridian Credit Union and Compass Bank.