Can we use our own KYC vendor to build our app using BaaS or RaaS?

tl;dr: No. You cannot.

When developing a product or app using Banking-as-a-Service (BaaS) or Remittance-as-a-Service (RaaS) platforms, it’s crucial to understand the limitations regarding Know Your Customer (KYC) and Know Your Business (KYB) processes. As a developer or service provider, your role is primarily to integrate with and utilize the APIs provided by the financial institution you’re partnering with.

It’s important to note that you’re not permitted to directly handle the flow of funds or independently manage compliance processes. The term “interfere” is used here to emphasize that any involvement in compliance must align strictly with the guidelines established by the financial institution supplying the APIs. This includes adhering to their technology and tools for KYC and KYB procedures.

The responsibility for ensuring transactional security, maintaining customer identity, and adhering to compliance standards rests with the financial institution, not with your service. Consequently, you cannot implement your own technology for KYC or KYB. This restriction exists because managing sensitive information like social security numbers, dates of birth, biometrics, passports, etc., requires specific licensing, which you as a service provider may not possess.

In summary, if you’re planning to create an app and wish to use your own methods for KYC or KYB, this will not be possible. You must use the KYC/KYB technologies and procedures provided by your BaaS or RaaS provider.

This page was last updated on January 17, 2024.

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