Trackwise applies a Know Your Customer (KYC) and Know Your Business (KYB) program built on a risk-based approach and aligned with the BSA / AML program described in our AML / BSA Policy.
1. Individual identity verification (KYC)
- Government-issued photo identification (passport, national ID, driver's license).
- Selfie with liveness detection, compared against the ID image.
- Address verification through document or authoritative database.
- Tax identifier where required.
2. Business identity verification (KYB)
- Certificate of incorporation / good standing.
- Articles of organization or bylaws.
- Beneficial-owner identification at 25% or greater ownership.
- One control person (e.g., CEO or equivalent).
- Description of business and source of funds.
3. Vendors
Identity verification is performed through specialized vendors. Vendors we may use include Persona, Sumsub, Veriff, Onfido, Au10tix, and Trulioo. Our choice of vendor depends on geography and product. All vendors are subject to vendor-risk review and contractual data-protection terms.
4. Enhanced due diligence (EDD)
EDD is applied when the customer or activity presents elevated risk, including:
- Politically exposed persons (PEPs) and their immediate family / close associates.
- Customers based in, or doing business with, high-risk geographies (e.g., FATF-listed jurisdictions).
- High-value or high-velocity transactions inconsistent with the stated profile.
- Adverse media or sanctions hits.
5. Refresh
Customer information is refreshed on a risk-based schedule. Higher-risk customers are reviewed more frequently.
6. Prohibited jurisdictions
Trackwise does not onboard customers located in, organized under the laws of, or ordinarily resident in jurisdictions subject to comprehensive U.S. sanctions or on the FATF call-for-action list. The list is reviewed and updated regularly.