Business and Compliance Information Questionnaire for Stablecoin-Based Inquiries

1. FinCEN Registration Status

  • Can your entity operate without FinCEN registration? Please explain your regulatory stance and any future plans regarding registration.

2. Licensing Plans

  • Do you have intentions to apply for specific licenses in the foreseeable future? Detail any planned licensing endeavors.

3. Flow of Funds

  • Could you provide a detailed explanation of the primary direction in which your funds are flowing? We are interested in understanding whether the majority of your financial transactions originate from the US and are directed towards the Rest of the World, or if the flow is primarily in the opposite direction. Gaining insight into the nature and direction of your funds’ flow is crucial for us, as it helps ensure that our banking services are aligned with international financial regulations and compliance standards. This information aids in the assessment of our risk management processes and supports our commitment to upholding the integrity of the financial system.

4. Stablecoin Transactions

  • Does your business model involve receiving Stablecoins from non-US sources, converting them into USD, and then transferring these funds domestically or internationally? Please describe this process.

5. Transaction Volume

  • What is your typical monthly transaction volume? Providing a 12-month projection with expected growth would be invaluable.

6. Market Readiness

  • How prepared are you for market entry? Please share your timeline and any pertinent details about your readiness.

7. KYC/KYB Information Collection

  • What types of KYC (Know Your Customer) / KYB (Know Your Business) information do you collect from international clients? Detail your information-gathering process.

8. Identity Verification Partner

  • Which identity verification service provider do you use? Understanding your partnerships helps us evaluate your compliance framework.

9. Average Transaction Value

  • What is the average value of transactions processed by your entity?

10. Daily Transaction Volume

  • On average, how many transactions does your entity process daily?

11. Transaction Purposes

  • What are the primary purposes of the transactions you handle, especially in relation to stablecoins? Please provide detailed examples.

12. Involvement with Venezuela

  • Does your business operation involve transactions with or from Venezuela? Our providers are compliant with operations involving Venezuela.

13. International Licenses

  • Do you hold operational licenses in countries other than the US? Please list these countries along with the types of licenses you possess, including those for which you’ve applied and are pending approval, any that you haven’t used, and those you’ve ceased using.

14. Stablecoin Usage

  • Which stablecoins does your business primarily use in transactions?

15. Transaction Example

  • Please provide an example of a typical transaction your business facilitates, including any relevant countries and the process flow.
  • Example: For instance, consider a scenario where a business in Argentina, facing capital controls, needs to pay a distributor in the United States for Black & Decker products. To facilitate this, the Argentine company converts their blue dollars into stablecoins by purchasing them from the local market. Then, they transfer these stablecoins to you. Next, you convert the stablecoins into fiat currency and proceed to make the payment to the distributor located in Chicago for the Black & Decker products. Assuming all necessary due diligence, such as KYC (Know Your Customer), KYB (Know Your Business), and identification of beneficial owners, has been completed, and all invoices are in order, the funds flow from Venezuela to the United States. This serves as an example of the process.

16. Banking Services Requirement

  • Which specific banking services are you seeking? (e.g., FBO Account, Sub-Accounts, Cards, ACH, RTP, FedWire, SWIFT IN/Out, API)

17. Term Sheet Expectations

  • What are your expectations regarding the term sheet? Please share realistic projections.

18. Funding Source

  • How is your entity funded? Detail the sources of your capital.

19. Compliance Officer

  • Do you have a dedicated compliance officer? If yes, kindly provide their LinkedIn profile URL.

20. Processing Volume History

  • What is the total US Dollar volume your entity has processed over the last two years under your other licenses?

21. Regulatory Notices

  • Have you received any cease-and-desist notices or been subject to regulatory warnings/fines in any jurisdiction?

22. Travel Rule Compliance

  • What travel-rule software or compliance measures are you implementing?

23. Information on Incoming Transactions

  • What information can you provide about the origin and details of incoming transactions to the US?

24. Additional Information

  • Please share any additional information you believe is pertinent for us to understand your business and compliance needs better.

This page was last updated on March 21, 2024.

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