Can You Require Less KYC in Special Circumstances?

Doing so is, for the most part, is hard for us. The financial services industry is highly regulated and there are defined minimal CIPs for most of our products.

As a company, we are regularly audited to make sure we remain compliant with a wide variety of financial regulations. Any exceptions to minimal KYC requirements heavily complicates this process. Lastly, Synapse and Synapse's bank partners are in agreement on the minimum KYC for each specific use case. We are not usually able to support exceptions in this area. Additionally, exceptions of this kind pose heightened risk to our platforms and is not recommended.

Do We Recommend Platforms Contract Vendors for ID Pre-Verification?

We don’t, specifically for ID images. We have found them to make unnecessary edits to the ID photos that make them harder for us to process.

Please note: While we provide KYC verification with all of our products, we encourage our platforms to take necessary precautions as well. This may vary based on the expected user base and services offered, among other factors. There are systems that offer additional verification services that our platforms may find beneficial; we recommend evaluating your needs internally.

Is There an Unusual Activity Report (UAR) Escalation Process?

While Synapse does monitor for unusual activity to assist our partner banks in their compliance with the Bank Secrecy Act reporting requirements, Synapse does not file SARs directly with FinCEN. Any platforms registered as MSBs, or otherwise required to file SARs (registered broker dealers) should remain vigilant in their reporting obligations. We do, however, encourage our platforms to report instances of fraud and or suspicious activity to Synapse for further review; our compliance team is equipped to perform further investigation.

Can you On-Board Foreign Users?

We have the capability to on-board foreign users, if certain conditions are met. In these cases we will work with the platform to define KYC requirements that take into account the documentation those users have available but that also fulfill the security needs of KYC collection.

How Are Sanctioned Countries Managed to Ensure No Transactions To/From/Within Those Countries Are Processed?

We block sanctioned countries automatically on our end both at the transaction level and the user address level. We continuously update this list. We recommend platforms also perform their own monitoring.

How Does Synapse Retain Customer and User Data?

All users must accept Synapse's Privacy Policy which explains the data we collect and how we use such data. Synapse keeps aggregated and anonymized data for internal research and development, risk mitigation and machine learning purposes. Further information about how Synapse uses and stores its users’ data is available in Synapse’s Privacy Policy.