I welcome you as the CEO and founder of COREDO. Since 2016 our team has accumulated deep experience in registering legal entities abroad, obtaining financial licenses, and AML consulting. Today I will share a practical approach to creating KYC policy for international groups that combines a unified KYC standard with local KYC adaptation to the requirements of the EU, Asia, and the CIS. This is not theory: these are solutions we apply for clients expanding business in the Czech Republic, Singapore, Dubai, or Estonia. In recent years we at COREDO have supported more than 120 cross-border structures where errors in KYC led to account blocks, license refusals, or repeated EDD reviews by banks. In most cases the problem was not “tough regulators” but the absence of a unified KYC logic at the group level – banks saw a fragmented picture of risks and shifted responsibility onto the client.
Why a unified KYC for scaling?
The key problem of the local approach is the absence of a single source of truth (single source of truth). As a result, the same UBO may be assigned different risk ratings in the EU and Asia, and when a bank requests information the group cannot quickly demonstrate the consistency of its AML position. For banks this is a direct red flag, especially in cross-border transactions and payment licenses.
The solution developed at COREDO is built on a global KYC risk appetite: we set common thresholds for PEP screening, sanctions lists (World-Check) and beneficiary checks. In practice the risk-based approach does not mean “checking everyone more strictly”, but differentiating control: low-risk clients pass fast-track CDD, medium-risk — standard onboarding with periodic review, high-risk — EDD with sources of funds, transactional logic and ongoing monitoring. This reduces the burden on compliance teams and speeds up scaling without increasing regulatory risk.
Key question: should a unified KYC standard be implemented or are local adaptations sufficient? The answer — a combination. FATF recommendations (40 principles) emphasize AML harmonization, but taking into account high-risk jurisdictions. Our experience at COREDO has shown: purely local approaches create desynchronization risks, especially during banks’ checks on the origin of capital.
Steps for implementing a global KYC framework
Start with an audit. The COREDO team conducts Customer Due Diligence (CDD) at the group level: mapping high-risk jurisdictions, analyzing the group’s capital structure and defining the global risk appetite. For a client from Asia registering an EU structure in Estonia, we integrated eKYC (electronic KYC) with eIDAS identification, providing remote verification without physical presence.
Step 1: Policy development. Create a KYC document for EU business (6AMLD requirements), KYC for Asian companies (Travel Rule IVMS) and a CIS adaptation. Important: KYC policy is not a static PDF “for the regulator”, but an operational tool. It must be embedded into onboarding processes, periodic review and escalation, with clear SLAs, responsible persons and decision logging. This is exactly what banks and licensing authorities expect during inspections. Include KYT monitoring, the shift from one-off KYC to continuous Know Your Transaction (KYT). COREDO practice: for a fintech group we set up RegTech for automation, logging verifications and ensuring KYC cybersecurity with data access controls.
Step 2: Local adaptation. A unified KYC standard is the core, but with overlays. In the EU we apply Enhanced Due Diligence (EDD) for PEPs and sanctions under 6AMLD. In Singapore — MAS guidelines on substance. In the CIS — focus on the beneficial ownership registry. Example: the European COREDO group helped synchronize with eIDAS regulations by implementing digital identity systems for digital onboarding.
Step 3: Appointment of an independent compliance officer. The role of an independent compliance officer is critical in international groups. They ensure compliance to the Board of Directors with veto power over onboarding and prepare independent reporting. For international groups it is essential that the compliance officer is independent from commercial pressure and has direct access to Board-level. EU regulators and those in Asia view this as an indicator of AML system maturity and trust in the group as a whole. In one project a COREDO officer blocked a high-risk client, saving the group fines under FATF recommendations.
Step 4: Transition to KYT and RegTech. The shift from KYC to continuous KYT monitoring pays off: ROI from a unified policy reaches 3–5x due to reduced fines (up to 10% of revenue under 6AMLD). KYT allows detecting deviations from the declared client profile: disproportionate turnovers, atypical counterparties, geographic shifts. These signals most often trigger SAR reports and bank investigations — and this is where RegTech delivers the greatest effect. We use regulatory technology (RegTech) for transaction logs auditing, Travel Rule compliance in EU-Asia transactions. For a client in Dubai we integrated Asian regulatory sandboxes for testing.
Cross-border KYC risk management
Unsynchronized procedures — the main headache. Risks: bank refusals, licensing delays (crypto, forex, payments). The COREDO team minimizes them through regulatory synchronization of KYC between the EU, Asia and the CIS. Example: when registering a payment company in Poland (NPI/SPI) we conducted CDD and EDD procedures, taking into account the Basel Committee and GDPR for cross-border data flows.
We determine the global risk appetite by target KYC markets: low-risk for EU retail, high-risk for Asian crypto. We implement sanctions-list screening and PEP (Politically Exposed Persons) checks. Plus internal system controls with logging of verifications. Frankly: there are challenges; the evolution of AMLD directives (the impact of 6AMLD on companies’ KYC procedures in 2025) requires annual updates. But with KYC/AML compliance from the COREDO group, they avoid 90% of problems.
Assessment of success and sustainability
Metrics: onboarding time (target <48 hours), % of successful bank verifications (>95%), ROI from compliance investments (30% reduction in operating costs). For CIS businesses the advantages of a global KYC framework are access to EU licenses without local mistakes. Our experience: a client with CIS roots opened a structure in the United Kingdom and Singapore, obtaining a banking license with harmonization of AML standards.
COREDO Practical Recommendations
- Group audit: Check KYC dossier storage for compliance with GDPR data protection.
- Automation: Implement eKYC with remote verification for high-risk jurisdictions mapping.
- Support: Provide Legal outsourcing for licenses – from crypto in Lithuania to forex in Switzerland.
- ROI calculation: Compare costs of duplicates (local KYC) vs. a unified framework, payback in 6–12 months.
In 2026 KYC ceased to be an auxiliary function — it is a strategic asset for the group. It affects time-to-market, cost of capital and banks’ trust. Companies that invest in a unified KYC framework scale faster and with lower regulatory costs.