Managed compliance

In a managed compliance program, your bank partner performs key Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance functions for you. This includes identity verification, sanctions screening, and transaction monitoring. You don’t develop or run your own BSA/AML compliance program. Through Increase’s technology, you provide customer data to the bank for decisioning, based on the bank’s Customer Identification Program. For how this compares to the customized compliance model, see Compliance programs.

Your platform still plays an essential operational role in a managed compliance program. That role includes collecting required customer information, supporting requests for more information, and helping resolve issues that come up during a review. You’ll also own other key activities outside BSA/AML compliance, such as the user interface, customer support, fraud monitoring, information security, third-party risk management, and appropriate marketing of bank services.

At onboarding

While onboarding your Program, the bank partner will collect a lighter set of documents from you than in the customized model. This will focus on your corporate and legal standing, your funds flow, and your information security and operational practices.

While onboarding your customers, you’re responsible for providing the required information about each of your customers. You can create Entities yourself through the Entity API or in the dashboard. Alternatively, you can use Hosted onboarding to have Increase collect the information directly from your customers. See the Platform implementation guide for the technical details.

How checks work

Identity verification, sanctions screening, and transaction monitoring are primarily automated. Some cases require manual review or additional documentation, and higher-risk customers may go through enhanced due diligence. Timelines vary depending on the review and how quickly follow-up information is available.

When an entity can’t be verified

Sometimes the bank can’t verify an entity, or a beneficial owner of a company, from the information you submit. When that happens, the bank will request additional documentation, usually an identity document such as a passport or driver’s license, for the person it couldn’t verify. You will handle communication to your end customers for further information.

See Hosted onboarding for more detail on follow-ups for that flow. See Entity validation for how outstanding requirements appear on an entity via API and how to resolve them.

Ongoing operations

Some ongoing compliance functions, including transaction monitoring, are performed for you as part of the bank’s compliance program. Your team should be prepared to:

• Respond to requests for additional information about a customer or business.
• Support customer remediation, such as collecting updated information or documents.
• Share relevant context for transaction or sanctions related reviews when requested.

If you observe unusual activity, or have context that may help with a review, upload the details to the Increase Dashboard. The bank will confirm receipt and may follow up if we need additional information. Consistent with Bank Secrecy Act / Anti-Money Laundering requirements, the bank may not be able to share the outcome of a review.

You’ll be responsible for other ongoing operational activities, like fraud monitoring, information security, customer support, and marketing bank services appropriately. Your bank partner will review specific policies and procedures for these activities upfront, and monitor these activities as you operate your program.