Onboarding checks, sanctions screening and fraud decisions

Your risk checks run before a payment or after it, in systems the authorization path never calls.

Symptoms in your system

  • Customers drop out during identity verification and nobody can tell you which step lost them.
  • Business onboarding stalls because ownership documents are checked over email, and the same company gets verified twice.
  • Companies incorporated in one country are declined because a founder lives in another, and every document check asks for a domestic address.
  • Sanctions screening runs as an overnight batch, so a payment can settle hours before the name is checked.
  • Fraud rules live in a spreadsheet, and the person who wrote them has left.
  • Chargebacks arrive for payments your rules approved, and nobody can reconstruct which rule let them through.

What we build

  • Identity verification runs inside signup, and a customer who needs manual review is told during the flow.
  • Business onboarding collects ownership, control and document evidence once, and the file an examiner asks for is the one the system already holds.
  • Ownership and control are verified as separate tests, so a 25 percent shareholder in one country and a CEO in another each clear the check where they live.
  • Cases the model cannot represent reach a reviewer with the evidence attached, so an unusual ownership chain is decided under the same risk policy as everything else.
  • Sanctions screening covers the customer and the payment before the money moves, so a hit stops the transfer while it is still yours to stop.
  • Fraud rules and scores are versioned, and any approved or declined payment can be replayed against the rules that decided it.
  • Decisions happen inside the authorization path, within the time the scheme allows, so a bad payment is declined at authorization and never becomes a chargeback.
  • Analysts work one queue with the customer, the device and the payment history in front of them, and clearing a false positive stops being an investigation.

Failures that surface a year later

  • Screening thresholds left at the vendor default, so the alert queue grows with volume and hiring is the only lever left.
  • Fraud rules written for one attack and never retired, so the customers they block are increasingly the good ones.
  • No record of why a customer was approved, so a sample an examiner picks turns into a reconstruction exercise.
  • Checks run once at signup with nothing watching afterwards, so an account whose behavior changes is still treated as it was on day one.
  • Verification wired to one country of residence, so a legal structure the form cannot hold is declined by a field validation and never reaches a reviewer.
  • Sanctions list updates on a schedule nobody owns, so a name added this week is screened next month.

Standards and rails

  • KYC and KYB programs
  • AML transaction monitoring
  • OFAC, UN and EU sanctions lists
  • Beneficial ownership and control tests
  • FATF recommendations
  • EMV 3-D Secure
  • Scheme fraud and chargeback monitoring programs

Risk work we have done

We built the fraud platform inside a US startup payment facilitator, rules and machine learning together, deciding in the authorization path in under 50 milliseconds.

Risk operators write rules in a language of their own and ship them without waiting for a deploy.

KYC, sanctions and OFAC screening ran as components of the same platform, covering onboarding and payouts inside the same flow.

Related work: Card data, tokenization and PCI DSS scope. Stablecoins and onchain settlement.