Skip to main content

Extreme Compliance

  • Insider Relationships
  • AML and Suspicious Activity

  • Additional verification for risky/large transfers

    • Support phone calling script "Hi this is First Last calling from BT regarding your recent attempt to transfer XX unit to a US state or foreign country"
    • "country resident. How are you doing today? ......... Could I please ask you one more thing? /// Please smile and enjoy the rest of your day."
    • Persona session verification
    • Detect transfers that need additional verification in the authorization server

  • (^ Which presumes elementarily) Authorization Server

    • Implement trustline on/off logic for affiliates (requires use of CBs)

  • Build Affiliation Automation Flow

    • Lambda function that can fetch affiliation status from full PII record
    • Lambda function that can amend affiliation statuses
    • Interface to add an account as an affiliate
    • Interface to remove affiliate status from an account
    • Way to make sure it only removes after 3 months

  • Who's Affiliated?

    • Figure out if children of insiders matter
    • Which employees? Only E&O?
    • JOBS Act Title V also excluded from the count securities held by persons who received the securities pursuant to an employee compensation plan rule 503