Consumer onboarding (KYC)
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:Option 1: Use the OMS KYC process
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)
- Liveness check
- Name, date of birth, address
- OFAC and PEP screening
Option 2: Bring your own KYC
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.Business onboarding (KYB)
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
Transaction monitoring (AML)
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
Regulatory coverage
The OMS compliance infrastructure operates money transmission directly under its own licenses: Money Transmitter Licenses in 37 US states plus exemptions in 11 more, covering 48 US states, alongside FinCEN registration as a Money Services Business. 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.
Frequently asked questions
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.Can a business customer receive funds from a bank account they don’t own?
Yes. Business customers support third-party on-ramps and off-ramps:
Pass-through transactions, where funds arrive from one third party and are immediately forwarded to another, are not supported.
Can an individual customer send funds to another person?
Not currently. Individual customers are limited to first-party transactions: money must move to and from accounts they own.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.
Can I use KYC/KYB I’ve already collected?
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.What information is required for counterparties?
Counterparties do not need full KYC/KYB onboarding, but you must provide basic details:What does “no nested flows” mean?
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.
- 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.
Which countries are blocked?
See Supported Jurisdictions for the full list of sanctioned and restricted jurisdictions, plus details on how restrictions are enforced per transaction.Building your own compliance stack
For teams building custom payment infrastructure outside the OMS, the following providers are used in production by payment applications on Polygon.Identity verification (KYC/KYB)
Transaction monitoring (AML)
Polygon does not endorse or provide support for third-party compliance providers. Regulatory requirements vary by jurisdiction. Consult legal counsel for your specific product.