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 |
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 |
| 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 |
| 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 |
| 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
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)
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
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 |