Risk & Compliance Controls

Overview of controls implemented to ensure regulatory compliance, fraud prevention, and risk management.

KYC/KYB & Onboarding Controls

Identity verification and due diligence for recipients

Recipient Verification Process

All recipients undergo identity verification before full platform access is granted. Verification requirements may vary based on entity type, transaction volume, and jurisdictional regulations.

Verification Partner: Sumsub

All verification procedures are performed by external partner Sumsub.com — a leading identity verification platform that provides automated KYC/KYB/AML compliance solutions. Sumsub uses AI-powered document verification, biometric checks, and liveness detection to ensure secure and compliant identity verification across 220+ countries.

1

Registration

Recipient submits registration information including business details, contact information, and intended use case.

2

Account Activation

Initial account created with limited functionality. Recipient can access dashboard but payouts may be restricted.

3

Document Submission

Recipient uploads required verification documents based on entity type and jurisdiction requirements.

4

Verification Decision

Compliance team reviews submitted information and documents. Decision: Verified, Not Verified, or Pending Additional Information.

5

Enhanced Due Diligence (if triggered)

Additional review for high-risk indicators. May include source of funds verification, beneficial ownership clarification, or additional documentation.

Verified Status

  • • Full receiving capabilities enabled
  • • Payout functionality activated
  • • Standard transaction limits applied

Not Verified Status

  • • Receiving may be limited or blocked
  • • Payouts restricted until verification
  • • Document request sent to recipient

Transaction Monitoring & Fraud Controls

Real-time and batch transaction monitoring

Rules Engine

Configurable rule sets evaluate transactions against defined criteria including amount thresholds, geographic patterns, and behavioral indicators.

Velocity Controls

Transaction frequency and volume monitoring. Limits applied per payer, recipient, payment method, and time window.

Screening Controls

Placeholder for sanctions, PEP, and adverse media screening. Implementation varies by regulatory requirements.

Monitoring Outcomes

Allow

Transaction proceeds normally without intervention

Challenge

Additional verification required (e.g., step-up authentication)

Hold

Transaction placed on hold for manual review

Review

Flagged for compliance review but not blocked

Decline

Transaction automatically rejected

Operational Controls & Auditability

Evidence retention and case management

Event Logging

All transaction events, status changes, and user actions logged with timestamps. Logs retained per regulatory requirements.

Case Management

Placeholder for case management system. Flagged transactions assigned to compliance queue for review and resolution.

Evidence Retention

Placeholder for evidence storage. Transaction records, verification documents, and correspondence stored for required retention period.

Note: Details may vary by PSP/acquirer integration and regulatory requirements.

Compliance Documentation • For Acquirer Onboarding

Details may vary by PSP/acquirer integration and regulatory requirements.