As I said before, it's not a matter of whether or not your KYC process will fail, it's simply when and what happens after that. It sounds like you have your head in the right place, but I can tell you from experience that verifying bank account ownership and expecting the ACH chargeback period to be sufficient to protect you is not enough (for one thing a lot of banks are simply not great adherents of the ACH rules). You're essentially on your own, and you'll need to protect yourself, not just "follow the rules," if that makes sense.
> and charging bank accounts is all done on the company side.
I'm not sure what you mean by that.
Anyway, my contact info is in my profile and I'd love to chat more off-HN about this and compare notes against what you guys are doing.