How the Open Money Stack handles KYC, KYB, AML, and transaction monitoring for regulated payment products.
Transaction request │ ▼1. Identity Verification KYC · KYB · document verification · biometric liveness checks · accredited investor checks │ ▼2. Sanctions & Watchlist Screening OFAC SDN list · PEP screening · global sanctions · adverse media · country risk │ ▼3. AML Transaction Monitoring velocity limits · pattern detection · onchain analytics · risk scoring · Chainalysis / TRM │ ▼Transaction approved SAR / CTR filing · audit trail · regulatory reporting · real-time alerts
The Open Money Stack includes compliance as a core layer, not a third-party add-on. KYC, KYB, AML screening, and transaction monitoring are built into the regulated fiat access infrastructure. Institutions can use the OMS compliance layer directly, or bring their own verification process where they already have one.
Every consumer transacting through the OMS must complete identity verification before their first transaction. This satisfies AML obligations across supported jurisdictions.There are two paths:
The OMS handles the full KYC flow on your behalf. Users complete identity and document verification through the built-in process. No additional identity infrastructure required.What is collected:
Government-issued ID (passport, driver’s license, national ID)
Organizations with an existing KYC process can pass verified user identities to the OMS directly. The OMS accepts KYC status from approved organizations, so users who have already been verified do not need to repeat the process.This is the preferred path for regulated fintechs, neobanks, and PSPs that already operate licensed identity verification.
For B2B and B2B2B flows, the OMS supports business onboarding with Know-Your-Business (KYB) verification. This is required for business customers transacting above standard thresholds or in regulated corridors.What is collected:
Legal company name and registration details
Date and jurisdiction of incorporation
Company type and tax identification number
Registered address
Ultimate Beneficial Owner (UBO): full legal name and identity verification
Business contact: phone and email
KYB is structurally similar to consumer KYC but scoped to the entity and its controlling persons. The OMS handles collection, screening, and ongoing monitoring.
Compliance does not end at onboarding. The OMS applies continuous transaction monitoring across all payment flows:
Onchain screening: every wallet address and transaction is screened against sanctions lists and risk databases before settlement
Risk scoring: transactions are scored in real time based on counterparty risk, geography, and behavior patterns
OFAC and PEP checks: applied at onboarding and re-screened on an ongoing basis
Suspicious activity: flagged transactions are reviewed before funds are released; reporting obligations are handled by the OMS compliance infrastructure
The OMS compliance infrastructure operates under Money Transmitter Licenses (MTLs) across 38 US states and internationally. Institutions building on the OMS inherit this coverage rather than obtaining it independently.
Request OMS compliance access
Request access to OMS compliance coverage and the related integration options.
What is the difference between first-party and third-party transactions?
First-party: a customer sends to or receives from an account they own.Third-party: a customer sends to or receives from an account owned by someone else.Business customers can do both first-party and third-party transactions. Individual customers are currently limited to first-party transactions only.
Do I need to onboard every end-user who instructs a payment?
Yes. Every customer who initiates a payment instruction must be onboarded through OMS. You cannot make payments on behalf of customers who have not completed onboarding.
A business that has completed KYB can initiate payments for its own treasury.
A business cannot initiate payments on behalf of its own end-customers unless those end-customers are separately onboarded.
This applies regardless of whether the payment is small or routine.
For US-resident individual customers, yes, if your organization has already verified them, we can accept that verification through a reliance KYC process rather than requiring re-verification. Your organization must meet enhanced due diligence requirements to use this.For other customer types and geographies, reliance KYC/KYB support is limited or not yet available. Contact your account team for current status.
Nested flows, also called “on behalf of” transactions, occur when a payment is instructed by a party that has not themselves been onboarded.OMS does not support nested flows. The entity instructing a payment must be an onboarded customer. If your product involves end-users directing payments, those end-users must be onboarded individually.Supported:
An onboarded organization ramps USD to USDC to fund its own operations.
An onboarded business customer initiates a payment they control.
Not supported:
An onboarded organization initiates a payment on behalf of one of its own customers who is not onboarded to OMS.
An onboarded customer instructs a payment on behalf of their downstream customer.
If your use case involves end-user-directed payments, reach out to your account team to discuss onboarding options.
See Supported Jurisdictions & Networks for the full list of sanctioned and restricted jurisdictions, plus details on how restrictions are enforced per transaction.
Polygon does not endorse or provide support for third-party compliance providers. Regulatory requirements vary by jurisdiction. Consult legal counsel for your specific product.
