Compliance programs
How compliance responsibilities are divided depends on your Program configuration and your bank relationship. For example, some businesses use Increase directly for their own operations rather than to serve customers. In that case, Program onboarding might apply, but the customer onboarding responsibilities and compliance models below do not.
This page explains the two most common models and what each means for onboarding and ongoing operations. For more information about the building blocks and key concepts referenced below, see Compliance overview.
Two common models
In a customized compliance program, you maintain your own compliance program for your business and your customers. Your bank partner supervises it through periodic and ongoing reviews. See Customized compliance.
In a managed compliance program, the bank directly performs key compliance functions for you. This includes identity verification, sanctions screening, and transaction monitoring. You don’t run your own compliance program. See Managed compliance.
In both cases, Increase’s APIs and dashboard are the common tool to track data, share reports, request updates, and manage customers.
Program onboarding means onboarding your Program with Increase and the bank. It’s the documentation and setup required before launch. Customer onboarding means onboarding your customers onto your Programs.
| Responsibility | Customized compliance | Managed compliance |
|---|---|---|
| Program onboarding | Full documentation set | Reduced documentation set |
| Customer onboarding | You run it | You run it |
| Identity verification (CIP) | You run it, supervised by bank | Run by bank |
| Sanctions screening | You run it, supervised by bank | Run by bank |
| Transaction monitoring | You run it, supervised by bank | Run by bank |
| Ongoing due diligence (CDD/KYC) | You run it, supervised by bank | Run by bank |
| Compliance program and policies | You maintain your own, supervised by bank | The bank conducts its BSA program directly |
| Ongoing | Evidence your compliance program; periodic reviews | Provide information, support follow-ups and remediation |
Regardless of which compliance model your Program uses, you are responsible for ensuring required customer information is collected and reported to Increase. What changes by model is who performs the underlying compliance functions and who owns the formal compliance program. Your exact model is determined when you onboard your Program with Increase and your bank partner, and can vary by bank partner and configuration.
For how to collect and submit customer information in practice, see the Platform implementation guide or Hosted onboarding.
Questions
If you’re not sure which model applies to you or what to expect, reach out to support@increase.com.