Crypto — Customer Onboarding

Overview

This guide covers FrankieOne’s KYC solution for cryptocurrency and digital asset businesses, designed to support multi-jurisdictional compliance requirements including AUSTRAC (Australia), FinCEN (USA), MiCA (EU), and global AML standards.

Summary

Available Workflows

Workflow	Purpose	When to Use
`GLB-IntlOnePlus`	Global identity verification	Multi-jurisdictional customer base
`USA-Basic1V-OnePlus`	USA identity verification	US-based customers (combine with biometrics)
`AUS-Risk-CDD-Email-Phone`	AU risk-based orchestration	Recommended for AU - Auto-routes to Basic3V or Advanced3V
`AUS-Basic3V-TwoPlusID`	AU standard verification	Australian customers, low-medium risk
`AUS-Advanced3V-TwoPlusID`	AU enhanced verification	High-risk, step-up scenarios
`GLB-AMLMedia`	AML screening	PEP, sanctions, adverse media checks

Multi-Jurisdictional Coverage

Jurisdiction	Regulatory Framework	Recommended Workflow
Australia	AUSTRAC DCE Registration	`AUS-Risk-CDD-Email-Phone`
USA	FinCEN MSB, State Licenses	`USA-Basic1V-OnePlus` + biometrics
European Union	MiCA	`GLB-IntlOnePlus` + address verification
Global	FATF Recommendations	`GLB-IntlOnePlus`

Quick Implementation Flow

Decision Outcomes

Outcome	Action
PASS	Create account, set transaction limits, enable trading
REVIEW	Queue for enhanced due diligence, request additional docs
FAIL	Block registration, log reason, display compliant message

MiCA Compliance Checklist

Requirement	FrankieOne Support
Name verification	✓ Supported
Address verification (full)	✓ Supported
Document verification	✓ Supported
Sanctions screening	✓ Supported
PEP screening	✓ Supported
Audit trail	✓ Supported

Support

Documentation: docs.frankieone.com
Support: Contact your FrankieOne representative

Expanded Details

Regulatory Context

Disclaimer: The information in this section is provided for general guidance only and does not constitute legal or compliance advice. Customers must seek independent legal and regulatory advice to ensure their implementation meets their specific regulatory obligations across all operating jurisdictions. FrankieOne is not responsible for customers’ compliance decisions or outcomes.

Regulatory Updates: Cryptocurrency regulations are rapidly evolving globally. Customers should monitor updates from relevant regulators (AUSTRAC, FinCEN, EU supervisory authorities, FATF) and ensure ongoing compliance.

AUSTRAC Digital Currency Exchange (DCE) Requirements

Australian Digital Currency Exchanges must register with AUSTRAC and comply with AML/CTF obligations.

Obligation	Requirement	How FrankieOne Can Support
Customer Identification	Verify customer identity before providing services	Automated identity verification with risk-based approach
Ongoing CDD	Monitor customers on risk-based schedule	Re-verification triggers and screening refresh (where configured)
AML/CTF Program	Maintain compliant program	Configurable risk rules aligned to your program
Transaction Monitoring	Monitor transactions for suspicious activity	Verified identity data and risk signals to support customer transaction monitoring systems
Reporting	Submit SMRs and threshold reports	Audit trails and exportable verification and audit data

MiCA (Markets in Crypto-Assets) Regulation - EU

MiCA introduces harmonised requirements for crypto-asset service providers (CASPs) operating in the European Union.

MiCA Requirement	Description	How FrankieOne Can Support
Customer Due Diligence	Verify identity of customers before onboarding	Identity verification workflows with EU document support
Name Verification	Verify customer’s full legal name	Name verification against authoritative sources
Address Verification	Verify customer’s residential address	Full address verification
Travel Rule	Originator and beneficiary information for transfers	Verification data to support Travel Rule compliance
Sanctions Screening	Screen against EU and international sanctions lists	PEP and sanctions screening included in workflows

Travel Rule Considerations

The FATF Travel Rule requires virtual asset service providers (VASPs) to collect and transmit originator and beneficiary information for transfers above thresholds.

Party	Required Information
Originator	Name, account number, address (or national ID, or DOB and place of birth)
Beneficiary	Name, account number

FrankieOne’s verification workflows collect identity data that can support Travel Rule compliance. FrankieOne does not transmit Travel Rule messages; these are handled by dedicated Travel Rule solutions.

Name and Address Verification

Full Address Verification Setup

MiCA and other regulations require verification of customer residential address. Required Address Components:

Component	Description	Example
Address Line 1	Street address including number	123 Main Street, Unit 4B
City	City or locality	Sydney, Berlin, Singapore
Postal Code	Postal/ZIP code	2000, 10115, 048624
State/Province	State, province, or region	NSW, Bavaria, N/A
Country	ISO country code	AUS, DEU, SGP

Address Verification Methods:

Method	Description	Coverage
Electronic Verification	Verify against authoritative data sources	Australia, EU, selected global
Document Verification	Extract and verify address from documents	Global
Utility/Bank Statement	Verify via uploaded proof of address	Global

Name Matching Considerations

Scenario	Handling
Transliteration variants	Fuzzy matching with configurable threshold
Name order differences (Eastern/Western)	Support both conventions
Hyphenated names	Normalisation before matching
Titles and suffixes	Strip before matching
Diacritics/accents	Normalise for matching

Workflow Configuration Details

Global Identity Workflow: `GLB-IntlOnePlus`

This workflow provides unified global coverage for crypto customer onboarding.

Region	Document Types	Verification Sources
Australia	Passport, Driver Licence, Medicare	Government (DVS), credit bureaus
European Union	Passport, National ID, Residence Permit	Government databases, credit bureaus
United Kingdom	Passport, Driver Licence	Government databases
United States	Passport, Driver Licence, State ID	DMV, credit bureaus
Asia Pacific	Passport, National ID	Varies by country

USA Identity Workflow: `USA-Basic1V-OnePlus`

Important: US Document Verification Limitations Unlike some jurisdictions, the USA does not have centralised government data sources for verifying Driver Licences or Passports via KYC checks. FrankieOne recommends:

Document Type	Recommended Verification Approach
Driver Licence	Biometric verification (document + face match)
State ID	Biometric verification (document + face match)
Passport	Biometric verification (document + face match)
Digital mDL	Coming soon - digital mobile Driver Licence verification

KYC Data Source Verification:

Check Type	Purpose	Source
Name and DOB verification	Identity confirmation	Credit bureaus, public records
SSN verification	Identity cross-reference	Credit bureaus
Address verification	Residential address confirmation	Credit bureaus, utility data
PEP and sanctions screening	OFAC and AML risk assessment	Sanctions lists, PEP databases

AU Risk Based Onboarding: `AUS-Risk-CDD-Email-Phone`

This orchestration workflow evaluates risk signals at verification start and automatically routes Australian customers to the appropriate verification path. Risk Signal Evaluation:

Signal	Risk Indicator
Email age	Recently created (under 30 days)
Email domain	Disposable email services
Phone type	VoIP phone numbers
Phone carrier	Country mismatch
IP geolocation	Misalignment with claimed residence
Device fingerprint	Velocity across multiple applications

Low Risk Path: AUS-Basic3V-TwoPlusID

Check Type	Purpose
Government ID verification (DVS)	Primary identity confirmation
Dual credit bureau checks	Identity cross-reference
Electoral roll	Address verification
PEP and sanctions screening	AML risk assessment

High Risk Path: AUS-Advanced3V-TwoPlusID

Check Type	Purpose
All Basic3V checks	Baseline verification
Biometric facial matching	Face-to-document match with liveness detection
Document authenticity	Fraud and tampering detection
Adverse media screening	Additional risk assessment
Enhanced address verification	Multiple source address confirmation

AML Screening Workflow: `GLB-AMLMedia`

Check	Description	Risk Levels
Sanctions Screening	OFAC, UN, EU, DFAT, and other lists	Match / Near-match / Clear
PEP Screening	Politically Exposed Persons (Levels 1-4)	Level indicated
Adverse Media	Negative news screening	Hits found / Clear
Watchlists	Law enforcement and regulatory lists	Match / Clear

PEP Levels:

Level	Description	Typical Action
PEP 1	Head of state, senior government	Enhanced due diligence required
PEP 2	Senior political figure	Enhanced due diligence required
PEP 3	Mid-level political figure	Review recommended
PEP 4	Associate or family member	Flag for awareness

Risk Tier Examples

Tier 1: Low Risk - Auto-Approve

Customer Profile:

Australian citizen
Valid passport
Address verified electronically
No PEP or sanctions matches
Low-risk jurisdiction

Example Scenario:

Emma Testone, 28, registers from Sydney, Australia. She provides her Australian passport and residential address. Identity verified against government records, address confirmed via electronic sources, no PEP or sanctions matches. Account activated with standard limits.

Tier 2: Medium Risk - Enhanced CDD

Customer Profile:

EU citizen (Germany)
Valid passport and national ID
Address requires document verification
No sanctions, PEP Level 4 (family member)

Example Scenario:

Hans Testtwo, 35, registers from Berlin, Germany. Identity verified via German national ID. Address electronic verification returns partial match. PEP screening identifies him as family member of a mid-level political figure (PEP Level 4). Proof of address document requested and verified. Account activated with enhanced monitoring flag.

Tier 3: High Risk - Manual Review

Customer Profile:

High-risk jurisdiction
PEP Level 2
Adverse media findings
High intended transaction volume

Example Scenario:

Alex Testthree, 42, registers with high intended trading volume. Jurisdiction is on FATF grey list. PEP screening identifies Level 2 status (senior political figure). Adverse media search returns articles about regulatory investigation (subsequently cleared). Case escalated to compliance team for enhanced due diligence review.

Tier 4: Auto-Reject

Trigger	Rationale	Action
Confirmed sanctions match	Legal prohibition	Block, file report if required
Prohibited jurisdiction	Regulatory restriction	Block with jurisdiction message
Document fraud detected	Fraud prevention	Block, flag for investigation
Age under 18	Regulatory requirement	Block
Duplicate account	Terms violation	Block

Jurisdiction Handling

Supported vs Restricted Jurisdictions

Category	Example Countries	Typical Handling
Fully Supported	Australia, Germany, UK, Singapore	Standard onboarding
Supported with EDD	High-risk FATF countries	Enhanced due diligence required
Restricted	Sanctioned countries	Block registration
Not Supported	Countries outside operating licence	Block with appropriate message

FATF Grey List Considerations

Customers from FATF grey list countries may require enhanced due diligence:

Additional identity documentation
Source of funds verification
Ongoing customer due diligence with screening refresh
Senior management approval

Edge Cases and Special Handling

Name Verification Edge Cases

Scenario	Example	Handling
Transliteration	Михаил → Mikhail / Michael	Fuzzy matching with transliteration support
Name order	Wei Zhang vs Zhang Wei	Support both conventions
Compound names	María José García López	Match full compound name
Single name	Sukarno (Indonesian)	Accept single name where culturally appropriate

Address Verification Edge Cases

Scenario	Handling
No postal code (some countries)	Mark as N/A, verify other components
PO Box address	Reject for residential, request physical address
New development (not in databases)	Document verification required
Rural address (no street number)	Accept descriptive address with document

Document Verification Edge Cases

Scenario	Handling
Passport in non-Latin script	MRZ verification + transliteration
Recently issued ID (not in database)	Document verification, flag for monitoring
Dual nationality	Accept either valid passport
Refugee travel document	Accept with enhanced verification

Compliance Reporting

Audit Trail Requirements

Data Category	Retention Period	Purpose
Verification requests	Per regulatory requirement	AML/CTF compliance
Document images	Per regulatory requirement	Evidence retention
Screening results	Per regulatory requirement	AML/CTF compliance
Decision outcomes	Per regulatory requirement	Audit trail

Note: Retention periods vary by jurisdiction (e.g., 7 years Australia, 5 years EU). Configure based on your regulatory requirements.

Travel Rule Data Support

FrankieOne verification data can support Travel Rule compliance by providing verified:

Full legal name
Account identifier
Address OR national ID OR DOB and place of birth

Troubleshooting

Issue	Likely Cause	Resolution
Address verification failing	Incomplete address components	Ensure all required fields collected
Name mismatch on foreign documents	Transliteration differences	Enable fuzzy matching
High false positive on sanctions	Common name	Tune matching thresholds
Jurisdiction incorrectly blocked	Configuration issue	Review jurisdiction settings

​Overview

​Summary

​Available Workflows

​Multi-Jurisdictional Coverage

​Quick Implementation Flow

​Decision Outcomes

​MiCA Compliance Checklist

​Support

​Expanded Details

​Regulatory Context

​AUSTRAC Digital Currency Exchange (DCE) Requirements

​MiCA (Markets in Crypto-Assets) Regulation - EU

​Travel Rule Considerations

​Name and Address Verification

​Full Address Verification Setup

​Name Matching Considerations

​Workflow Configuration Details

​Global Identity Workflow: GLB-IntlOnePlus

​USA Identity Workflow: USA-Basic1V-OnePlus

​AU Risk Based Onboarding: AUS-Risk-CDD-Email-Phone

​AML Screening Workflow: GLB-AMLMedia

​Risk Tier Examples

​Tier 1: Low Risk - Auto-Approve

​Tier 2: Medium Risk - Enhanced CDD

​Tier 3: High Risk - Manual Review

​Tier 4: Auto-Reject

​Jurisdiction Handling

​Supported vs Restricted Jurisdictions

​FATF Grey List Considerations

​Edge Cases and Special Handling

​Name Verification Edge Cases

​Address Verification Edge Cases

​Document Verification Edge Cases

​Compliance Reporting

​Audit Trail Requirements

​Travel Rule Data Support

​Troubleshooting

Overview

Summary

Available Workflows

Multi-Jurisdictional Coverage

Quick Implementation Flow

Decision Outcomes

MiCA Compliance Checklist

Support

Expanded Details

Regulatory Context

AUSTRAC Digital Currency Exchange (DCE) Requirements

MiCA (Markets in Crypto-Assets) Regulation - EU

Travel Rule Considerations

Name and Address Verification

Full Address Verification Setup

Name Matching Considerations

Workflow Configuration Details

Global Identity Workflow: `GLB-IntlOnePlus`

USA Identity Workflow: `USA-Basic1V-OnePlus`

AU Risk Based Onboarding: `AUS-Risk-CDD-Email-Phone`

AML Screening Workflow: `GLB-AMLMedia`

Risk Tier Examples

Tier 1: Low Risk - Auto-Approve

Tier 2: Medium Risk - Enhanced CDD

Tier 3: High Risk - Manual Review

Tier 4: Auto-Reject

Jurisdiction Handling

Supported vs Restricted Jurisdictions

FATF Grey List Considerations

Edge Cases and Special Handling

Name Verification Edge Cases

Address Verification Edge Cases

Document Verification Edge Cases

Compliance Reporting

Audit Trail Requirements

Travel Rule Data Support

Troubleshooting