Field Guide
Identity and trust: KYB, KYC and ongoing monitoring
03
How to choose
1 min read · Chapter 3 of 10
Choosing what to check: five questions
- Who holds the legal duty? A bank, a licensed money transmitter, a marketplace under the INFORM Consumers Act, or nobody, because you're a B2B software company checking for fraud reasons. That sets your floor, and if there's a bank, its program sets the bar.
- How fast can money leave? Instant payouts and instant credit lines put the loss right after onboarding, so check more up front. A product where money moves slowly can approve with limits and lean on monitoring.
- Who are your applicants? Most US small businesses have no employees (about 30 million of 36 million), and many are sole proprietors with no registry record at all. For them the work is the person and what the business really does. The ownership graph starts to matter with mid-market and cross-border customers.
- Where are they from? It depends on where they were formed and where the owners live. A Delaware check costs money per lookup, a UK company is free to query, EU ownership registers are mostly closed to you, and an owner abroad has no SSN and no US credit file.
- What must you prove? Your bank or network will ask. Sponsor banks and auditors want to see, for every field, which source it came from and when. If you can't show that, it doesn't count as checked.
My defaults: for people, data checks come first and a document plus selfie is the step-up when the data isn't enough. For businesses I'd pull the registry record, the EIN match and the change history, since a match on its own says little. Store the ownership graph with dates and sources. Approve with limits and relax them on good behaviour. Subscribe to registry changes where you can. Size the monitoring team for next year's volume, and spend on what happens after approval at least as carefully as on the front door.