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Compliance requirements

If you move money on behalf of your clients, this document is for you! This includes those opening For Benefit Of (FBO) accounts or those opening accounts on behalf of their underlying users. This does not include OAuth users. These users are agents of the entity they are moving funds on behalf of.


For benefit of (FBO) account holders are Program Managers of the bank. You are required to maintain a full compliance program. This includes, but is not limited to, Bank Secrecy Act compliance and any applicable consumer protection regulation.

We’ll provide you with a compliance questionnaire and a document checklist. After you’ve submitted the documentation, we’ll assess your business’s risk. We might have some follow-up requests.

If you’re at the beginning of your journey, we’d strongly advise working with a consulting firm to help pull together a robust compliance program.

Ongoing requirements

Customer information files

You collect and verify the information about your customers. You must share that with us, however. To do so, you create an Entity. You can differentiate between your customers’ entities, your entities, and any other kind of entity using the relationship property. In particular:

  • Affiliated entities are entities you own and control.
  • Unaffiliated entities are your customers’ entities. An unaffiliated entity must be on file for every client onboarded.
  • Informational entities are when you’re submitting details to us but there’s no relationship or service provided by the bank to your customer. This is rarely used.

Transaction monitoring and suspicious activity reporting

As part of your compliance program, you’ll monitor transactions for signs of money laundering, terrorist financing, and other illicit financial activity. As you’re monitoring transactions and reviewing customer identification documents you’ll come across unusual activity. When you do, you must review it, validate that it is not expected behavior, and submit the details to

We’ll acknowledge we’ve received your email but we won’t provide feedback or follow up unless we need help. This is a Bank Secrecy Act / Anti-Money Laundering requirement.

Standard Periodic Program Review

  • Quarterly, we will discuss program updates and new risks with your Chief Compliance Officer.
  • Annually, we will review your refreshed documents and any changes to your policies or procedures.
  • We will periodically audit your identity verification procedures as needed.