Customized compliance
Under customized compliance, you maintain your own compliance program for your business and your customers. This includes identity verification, customer due diligence, sanctions screening, and transaction monitoring, as well as the supporting policies, procedures, and controls. Your bank partner requests documentation about your program, supervises it, and conducts periodic reviews. For how this compares to managed compliance, see Compliance programs.
If you’re at the beginning of your journey and customized compliance is the right model for your Program, we strongly advise working with a consulting firm to help pull together a robust compliance program. We’re happy to recommend firms to work with. If you have questions, reach out to support@increase.com.
What we collect at Program onboarding
A lot of information is collected during Program onboarding. Your bank partner will look for information across the areas below. They may have some follow-up requests and provide feedback to help you develop policies and procedures that align with their expectations and risk tolerance.
| Category | What the bank is looking for |
|---|---|
| Regulatory compliance | Anti-money laundering procedures, compliance management policies, your terms of service |
| Business experience and qualifications | Your business’s size, staffing, and products |
| Financial health | Financial statements, audit reports, and forecasts |
| Risk management and controls | Vendor management, current vendors, how your business assesses counterparty risks |
| Information security | Data protection systems, network diagrams, software development lifecycle |
| Operational resilience | Business continuity, penetration tests, insurance policies |
Customer information and identity verification
You’re responsible for verifying the identity of your customers through your own Customer Identification Program. See the Platform implementation guide for how to submit customer information and attach verification evidence.
The bank will evaluate each Entity’s submitted data against your identity verification policy and rules that were approved during onboarding.
Transaction monitoring
As part of your compliance program, you’ll monitor transactions for signs of money laundering, terrorist financing, and other illicit financial activity. When you come across unusual activity, review it, validate that it isn’t expected behavior, and submit the details to the Increase dashboard. Your bank partner will confirm receipt and may follow up if they need additional information. Consistent with Bank Secrecy Act / Anti-Money Laundering requirements, they may not be able to share the outcome of a review.
In addition to escalated findings, you’re expected to submit evidence of all your alerts. The bank will use this data to ensure that you’re following the transaction monitoring policy and rules that were approved during onboarding.
Periodic compliance review
- Annually, your bank partner will review your refreshed documents and any changes to your policies or procedures.
- Annually, your bank partner will review your website, terms & conditions, and fees.
- Quarterly, your bank partner will discuss compliance program updates and new risks with your compliance lead.
- Your bank partner will periodically audit your identity verification procedures as needed.
- Your bank partner will periodically request audited financial statements, if applicable.
If your Program serves consumers, additional requirements apply. See Consumer Program requirements.