Atlas for Fintech

Everything you need to know about Atlas for Fintech's Model

Atlas for Fintech is designed for regulated financial institutions that want to embed Verto's payment and FX infrastructure to serve their own underlying clients. You retain the compliance relationship with your clients — Verto assesses your internal controls and places a level of reliance on your existing framework.

Who it's for

  • Fintechs, digital banks, and neobanks
  • Payment Service Providers (PSPs) and Payment Service Businesses (PSBs)
  • Money Service Businesses (MSBs) and Money Transfer Operators (MTOs)
  • Brokers and financial intermediaries
  • Any directly licensed and regulated financial institution

Core use cases

Atlas for Fintech supports two distinct flows depending on your product and the nature of your underlying clients. These can be used independently or together.

Collections on behalf of (COBO) — Sub-accounts

Receive funds into a sub-account on behalf of a corporate underlying client. Funds are collected and allocated to the client's isolated sub-account wallet. Each sub-account has its own unique collection account details.

Supported for corporate underlying clients only (B2B). Consumer clients are not supported under Atlas for Fintech.

See the Sub-accounts — Atlas for Fintech guide for full integration details.

Payments on behalf of (POBO) — Global Clearing

Make outbound payments on behalf of an underlying client across local rails, SWIFT, stablecoin & mobile money. Supported for both corporate and individual underlying clients.

Payments can be originated from a sub-account wallet or directly from a master (parent) wallet. Where payments originate from the master wallet, a sender object is required to identify the underlying client. Where payments originate from a sub-account, sender information is inherited from the sub-account's KYB data.

See the Global Clearing guide for full integration details.

How the compliance model works

Access to Atlas for Fintech requires a Downstream Service Assessment completed by Verto's compliance team regardless of which flow you are using. This is a one-time review of your organisation's compliance framework that determines your eligibility and, for sub-account flows, the level of reliance Verto places on your KYB/KYC processes.

Sub-accounts (COBO)

For sub-account flows, the outcome of the Downstream Assessment determines how much information Verto collects on each underlying client:

LevelWhat it meansEligibility indicators
Level 0 (highest reliance)Verto collects minimal information on your end-clients, subject to quarterly reviewsIndependent AML/FinCrime compliance audit from a reputable firm in the last 12–18 months
Level 1–2Verto collects minimal information plus some documentation, checked ad-hocStrong compliance function, dedicated MLRO, automated transaction monitoring — but no Tier 1 audit report
Level 3Full documentation collected per sub-account, equivalent to direct onboardingNo independent audit, small or developing compliance function — consider Atlas for Platform

Global Clearing — POBO from master wallet

For payment-on-behalf-of flows initiated from the master wallet, the Downstream Assessment is required as a prerequisite for access, but the reliance level does not govern per-payment data collection in the same way. Instead, compliance requirements at point of payment are met through the sender object — which must be included in every payout request to identify the underlying client originating the payment.

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Initiating downstream payment flows without completing the Downstream Assessment and receiving compliance approval will result in transactions being flagged and your account being suspended.

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If your organisation does not have a directly held licence, lacks a dedicated MLRO, or cannot provide an independent AML/compliance audit, you are unlikely to pass the Downstream Assessment and should be directed to Atlas for Platform instead.

When Atlas for Fintech is not suitable

The following scenarios should use Atlas for Platform instead:

  • Your organisation operates under a partner's licence rather than a directly held licence
  • You want to offer USD, GBP, or EUR sub-account collection accounts (COBO) — G10 currencies are only supported for collections under the Platform model. Note that Global Clearing (POBO) payouts in G10 currencies are supported under Atlas for Fintech.
  • You provide services to other financial institutions (double nesting is prohibited)
  • You do not have an independent AML/FinCrime compliance function

The following scenario is not currently supported across any Verto model:

  • Collections on behalf of individual underlying clients — COBO flows are supported for corporate clients only. If this is a requirement for your use case, contact [email protected] to discuss.
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Before go-live, downstream assessment must be completed, your sales/account manager can help with this. If you don't have a sales/account manager contact [email protected] to get one assigned.


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