never reconciled
The wallet was checked and the person was identified, but no one linked the two. Since wallet-risk tools and name-screening tools generally do not use the same customer ID, a discrepancy between the two doesn't appear automatically.
For exchanges, custodians and digital asset platforms, sanctions and adverse-media checks are carried out on both the wallet address and the identity associated with it, and this process continues each time the wallet carries out a transaction, and not just on the day the account is opened.
A wallet address and the identity behind it are two different things, and most stacks screen only one of them well.
complead combines the wallet ID with the claimed identity into one entity before checking either of them and then retains that entity within its scope for as long as the account remains active, not just for the day that the account was opened.
Wallet exposure and name checking are generally purchased separately and then examined separately. The audit focuses on a single customer, and the response has to be put together from two systems which had never agreed on who that customer was.
The wallet was checked and the person was identified, but no one linked the two. Since wallet-risk tools and name-screening tools generally do not use the same customer ID, a discrepancy between the two doesn't appear automatically.
One transfer, several thresholds. Each jurisdiction on the route sets its own minimum amount and required fields, and the receiving VASP has no built-in way to verify what the sender reported before crediting the funds.
Authorization is granted on a fixed date. Disclosure, conduct and ongoing reporting duties continue after it, and the team has to carry them out.
Before any of them is screened, the wallet address or the wallet ID that it resolves to is combined with the claimed identity into a single entity.
The wallet and the name are screened on the same entity: the wallet for chain exposure, the person for sanctions, PEP and adverse media.
The information regarding the originator and the beneficiary is swapped on a jurisdictional basis, and the information received from the other party's VASP is treated as a claim to be verified, not as a fact to be accepted.
The investigator looks at the wallet and identity evidence in one location, and this is also included in the export. In the case where that wallet is linked to another one which is already in your system, the link appears on the same case and not as a separate lookup.
Licensing was obvious and limited, while the continuing obligations were neither obvious nor limited, which is why the supervisor returns for them.
Read the compliance guidesTwo vendors produced two verdicts on the same counterparty. Moving both onto one entity record meant the investigator stopped reconciling and started deciding.
Yes. The wallet address and the identity behind it are screened against sanctions, PEP and adverse media on the same entity, in one step. Screening continues each time the wallet transacts, not only on the day the account is opened.
On the same entity record. Wallet screening and name screening write to one record, so a clean name with a flagged counterparty, or the reverse, appears as one risk rather than two results in two tools. The investigator sees the exposure next to the customer's identity checks.
The wallet is combined with the claimed identity into one entity before either is screened. Both checks then write to the same record, so the result does not depend on reconciling a wallet-risk tool and a name-screening tool that never shared a customer ID.
No. The entity stays in scope for as long as the account is active, and its wallets and counterparties are rescreened as lists change. In crypto, exposure usually arrives later, through a counterparty or a newly designated address, not at signup.
Yes. Its output lands on the same entity record as the name screening, so wallet exposure and identity checks are reviewed together. Most exchanges already run a chain analytics provider, and replacing it is not a condition of joining the two views.
More than thirty, with exposure attributed to mixers, sanctioned services and darknet markets. Attribution sits on the entity record next to the identity checks, so the analyst sees who the customer is and where their funds have been in one place.
Originator and beneficiary data is exchanged per jurisdictional threshold, which varies: the EU applies the Travel Rule to every transfer, while many other regimes start at around USD or EUR 1,000. What arrives from the counterparty VASP is stored as a claim to verify, not as verified identity, and is checked against the same entity record rather than trusted on arrival.
They are screened like any other wallet and linked to the customer's entity. Under the EU Transfer of Funds Regulation, transfers above EUR 1,000 to or from a self-hosted wallet also require you to verify that the customer owns or controls it, and that verification belongs on the same record as the screening.
Yes. If a wallet links to one already in your system, the link appears on the same case, not as a separate lookup. Wallet and identity evidence sit in one place and go into the same export, which is often where a set of accounts controlled by one person first becomes visible.
Ongoing conduct, disclosure and reporting duties that last as long as the authorization does, alongside Travel Rule data on every transfer and suspicious transaction reporting to the FIU. Supervisors return for these, not for the application. Each obligation draws on the same entity record, so the evidence stays consistent across all of them.
Bring one counterparty you have investigated twice. We will show you what it looks like as one record.