KYC & Compliance Requirements

Use this page to understand which KYC or KYB model applies to your integration, what data Verto requires for sub-accounts, and when compliance state blocks operational actions like wallet creation, account issuance, or payouts.

[!IMPORTANT] General Prerequisite: Parent Entity Onboarding Regardless of model, the Parent Entity (you) must complete full Verto compliance clearance, pass standard onboarding requirements, and complete platform registration before any Atlas sub-accounts can be activated.

✅ Before you review KYC requirements

Answer these questions first:

Are you integrating as Atlas for Fintech or Atlas for Platform?
Who owns the end-customer compliance process: your business or Verto?
Do you need downstream customers to receive funds, hold balances, or send payouts?
Are you ready to store and track compliance state for each sub-account in your own system?

⚖️ Model Comparison

	🏦 Atlas for Fintech	🏢 Atlas for Platform
Framework	Reliance Model	Non-Reliance Model
Designed for	Regulated Financial Institutions	Non-financial businesses (SaaS, E-commerce, Payroll) & White-Label Brokers
Who does KYC?	The FI (you) — Verto relies on your controls	Verto — Absorbs full regulatory liability
Sub-accounts classified as	Under your umbrella	Direct "Referred Clients" of Verto
KYC Tiers	Level 0, 1, or 2 (based on assessment)	Level 3 (always)

This model decision affects onboarding, operational approvals, and which downstream flows you can activate in production.

🏦 Atlas for Fintech — The Reliance Model

Verto places regulatory reliance on your internal compliance controls. Before activation, all Fintech partners must complete a Downstream Service Assessment to determine which KYC tier applies.

If you operate in this model, the quality of your own compliance program determines how much sub-account documentation Verto still requires.

🔍 The Downstream Service Assessment

Verto evaluates your compliance infrastructure across:

AML/FinCrime programme maturity
Quality and independence of MLRO function
Presence of automated transaction monitoring
External audit history (Tier 1 consulting firm)

Based on the outcome, you are assigned one of three KYC tiers:

🟢 Level 0 KYC — Highest Reliance

Eligibility: Highly regulated Financial Institutions that have passed Verto's rigorous Nested Assessment AND possess a mandatory FinCrime/AML Audit from a reputable Tier 1 consulting/audit firm.

Requirements (per sub-account):

Company Name
Registered Address
Industry / Business Type

Monitoring: Quarterly reviews by Verto Compliance.

🟡 Level 1 KYC — Standard Reliance

Eligibility: Highly regulated MSBs, PSPs, and Brokers with a strong, dedicated compliance function (independent MLRO, automated transaction monitoring), but lacking a Tier 1 audit report.

Requirements (per sub-account):

All Level 0 information, plus:
Certificate of Incorporation (CoI)
Ultimate Beneficial Owner (UBO) IDs
Power of Attorney (PoA) where applicable

Monitoring: Ad-hoc checks by Verto Compliance.

🔴 Level 2 KYC — Limited Reliance

Eligibility: Regulated MSBs, PSPs, and Brokers with developing compliance processes.

Requirements (per sub-account):

All Level 1 requirements, plus:
Random sample of sub-accounts reviewed by Verto Compliance for ongoing monitoring.

Monitoring: Ongoing random sampling.

[!CAUTION] Downstream Assessment Failure If your institution fails the Downstream Service Assessment (e.g., lacks an AML audit, inadequate compliance infrastructure, or no independent MLRO), you are restricted from the Reliance Model. You will be routed to the Atlas for Platform model (Level 3 KYC) instead.

🏢 Atlas for Platform — The Non-Reliance Model

All Platform sub-accounts are subject to KYC Level 3. Verto absorbs the full regulatory liability and treats every sub-account as a direct "Referred Client."

In this model, a sub-account should not be treated as operationally ready until Verto has completed the required review and approval steps.

📋 Level 3 KYC — Full Direct KYC

Applies to: All Atlas for Platform sub-accounts without exception.

Requirements (per sub-account):

Requirement	Detail
Full KYC Documentation	Complete KYC details and documents for every sub-account, exactly as if Verto were onboarding the end-user directly.
Compliance Review	Every sub-account must be fully reviewed and approved by the Verto Compliance team before activation.
T&C Acceptance	A company director from the end-client must formally accept Verto's Terms & Conditions and the Partner Access Agreement via electronic signature.

📊 KYC Tier Matrix

Level	Model	Eligibility	Data Collected	Monitoring
Level 0	Fintech	Tier 1 AML Audit + Nested Assessment pass	Company Name, Address, Industry	Quarterly
Level 1	Fintech	Strong MLRO + TM, no Tier 1 audit	Level 0 + CoI, UBO IDs, PoAs	Ad-hoc
Level 2	Fintech	Developing compliance	Level 1 + Verto sampling	Ongoing random
Level 3	Platform	All Platform partners	Full KYC docs + T&C signature	Continuous

🔄 Platform Sub-Account Onboarding Workflow

For Atlas for Platform partners, the activation flow follows a strict 4-stage pipeline:

sequenceDiagram
    participant P as Parent Account (You)
    participant V as Verto Compliance
    participant D as End-Client Director

    P->>V: 1. Submit sub-account KYC info + documents (via API or Dashboard)
    V-->>P: Status: KYC Pending
    V->>V: 2. Verto Compliance reviews documents
    V-->>P: Status: T&C Pending (KYC Approved)
    P->>D: 3. Trigger T&C email (select Director from dropdown)
    D->>V: 4. Director signs Partner Access Agreement + T&Cs
    V-->>P: Status: Approved — sub-account is now ACTIVE

Stage	Action	Status
1. Document Submission	Parent submits KYC via API or Verto dashboard	`kyc_pending`
2. Compliance Review	Verto Compliance reviews all documents	In Review
3. T&C Trigger	Parent selects Director; automated email sent	`tc_pending`
4. Director Sign-off	Director accepts T&Cs via electronic signature	`approved` / ACTIVE

[!NOTE] API vs. Manual Submission: For high-volume platforms, Verto recommends API-based document submission for scale. Manual submission via the Verto dashboard is available for lower-volume onboarding.

Operational impact of compliance state

Use compliance state as a hard operational control in your application:

Compliance state	What it means for your app
Pending / In review	Do not allow wallet creation, account issuance, or payout execution for that customer.
T&C pending	Keep the customer in onboarding until the required sign-off is complete.
Approved / Active	Customer can proceed into wallet, receive, FX, and payout flows that your account is approved to use.
Rejected / Suspended	Block operational actions and surface a remediation path to your internal ops or compliance team.

Troubleshooting

Issue	What to check
Sub-account never becomes active	Confirm all required documents were submitted and any T&C acceptance step has been completed by the correct party.
Wallet or account creation is blocked	Check whether the sub-account is still pending review or has not reached an approved operational state.
Platform onboarding does not scale	Use API-based document submission and store compliance status changes in your own system for automated follow-up.

🎯 Next Steps


Sub-Accounts Guide → Create and manage downstream customer contexts.	Go-Live Requirements → Review parent-account compliance prerequisites and production approvals.

Talk to Verto

Get help with authentication, receive flows, wallets, FX conversion, payouts, or Atlas platform setup.

Plan your go-live

Review the requirements you need before moving your integration into production.