Compliance & Risk Framework

Disciplined pre-screening,
institutional posture.

Every operator we represent and every licensed counterparty we partner with moves through the same disciplined pipeline. This page documents what that looks like — what we screen, what we decline, and how we monitor over time.

Pre-Screening Pipeline

What we check before any introduction.

Pre-screening exists to protect both sides of the table. Operators don't waste four weeks chasing a 'no'. Counterparties don't receive submissions that were never going to clear underwriting. The process below is uniform across verticals — adjusted in depth by risk tier.

01

Entity & UBO

  • Incorporation documents
  • UBO chain to natural persons
  • PEP & sanctions screening
  • Adverse media check
02

Licensing & Regulatory

  • Operating licenses in home jurisdiction
  • Vertical-specific authorizations
  • Cross-border permissions
  • Outstanding regulator actions
03

Business & Volume

  • Processing history (12-month)
  • Chargeback ratio and trend
  • Refund and dispute posture
  • Settlement banking history
04

Risk & Geography

  • Customer geography distribution
  • Sanctioned-jurisdiction exposure
  • Industry risk weighting
  • Card scheme alignment
Scope & Boundaries

What we work with — and what we decline.

We are selective about vertical scope. Some sectors fit our network; others don't — and we say so before we waste anyone's time.

In scope — actively supported

  • Licensed iGamingMGA, UKGC, KGC, AGCO, Curaçao reform-compliant operators
  • Regulated crypto & digital assetsMiCA-aligned, VASP-registered, FINTRAC-registered MSBs
  • Forex & CFD brokersCySEC, FCA, ASIC, FSCA, FSA-authorized
  • High-risk e-commerceNutra, digital goods, subscriptions in compliant markets
  • B2B fintech & SaaSEmbedded finance, treasury, marketplace platforms
  • FX & remittanceLicensed money services, cross-border payments

Out of scope — actively declined

  • Unlicensed gamblingOperators without a recognized license in their target market
  • Sanctioned jurisdictionsOFAC, EU, UN sanctions lists — no exceptions
  • Restricted adult contentCard-network restricted segments, non-consenting content
  • Pharma without prescriptionSchedule II–IV substances, controlled substances
  • Shell-structured operatorsOpaque ownership, anonymous UBOs, layered nominee structures
  • Crypto privacy mixersMixing, tumbling, privacy-coin-only operations
KYB Tiering

Three operator risk tiers.

Documentation depth scales with risk. Low-risk verticals in mature jurisdictions move on standard packets. Higher-risk profiles require enhanced due diligence and additional commercial structuring.

Tier
Profile
Documentation
Timeline
Tier 1
Low-risk · EU/UK e-commerce, regulated B2B fintech, licensed brokers in mature jurisdictions
Standard KYB · UBO declaration · 6-month statements · License copies
3–7 days
Tier 2
Medium-risk · Licensed iGaming, regulated crypto, high-risk e-commerce, MENA & LATAM operators
Enhanced KYB · Full UBO chain · 12-month statements · AML policy · Risk officer interview
7–14 days
Tier 3
High-risk · First-time corporate structures, multi-jurisdiction crypto, frontier-market operators
Full EDD · Independent legal opinion · Source-of-funds documentation · Site visit if required
14–30 days
Ongoing Monitoring

Compliance doesn't end at MID issuance.

Once an operator is live, the licensed counterparty owns the regulatory relationship. We support the operator through that ongoing relationship and surface friction early.

Transaction monitoring oversight

The licensed counterparty operates real-time TM and AML monitoring. We support operators in responding to alerts, providing context, and preparing for periodic reviews.

Quarterly performance review

Approval rates, chargeback ratios, fraud trends, and dispute outcomes — reviewed each quarter with both the operator and the counterparty. Adjustments to routing or commercials made on data.

Regulatory change tracking

MiCA, PSD3, scheme rules, FINTRAC amendments — we track changes across the regulatory regimes our partners operate within and brief operators on what affects them.

Next step

Ready to start the pre-screening conversation?

If your operation fits the in-scope profile above, we'd like to talk. Submit a partnership inquiry — a senior partner will respond within one business day.

Submit Partnership Inquiry