KYC policy of international groups a single standard or local adaptation

Nikita Veremeev

14.01.2026 | 6 min read

Updated: 14.01.2026

In international groups the question of a KYC policy today sounds very direct: a single standard or local adaptation? As someone who has been developing COREDO since 2016 and sees live cases from the EU, Asia and the CIS every day, I will confidently answer: formally, a single framework is needed; practically — without thoughtful local adaptation the business simply will not survive.

Why the old KYC approach does not work

• payment systems,
• correspondent accounts,
• licenses (crypto, EMI, PI, forex, investment),
• marketplace ecosystems and fintech partners.

• Each jurisdiction requires it “a little differently”: forms, timeframes, documents, EDD levels.
• Payment partners and banks practice over-compliance: they check every client and every transaction, block accounts, and require KYC updates “more often than is written in the law.”
• Scaling into 5–10+ countries turns into chaos: different procedures, different IT systems, different interpretations of AML risks in subsidiaries.

Group-wide KYC standard: components and requirements

• Risk appetite and client typologies
  • retail, SME, corporate, financial institutions;
  • high-risk segments: CBI clients (investment migration), crypto brokers, PSPs, P2P platforms.
  • logic: whom you are willing to serve at all, and whom: not in any country.
• KYC classification and verification levels
  • standard verification,
  • enhanced due diligence (EDD),
  • enhanced checks for PEPs, sanctioned and CBI clients.
  Uniformity is important here: if EDD for a corporate client in one subsidiary includes an analysis of the origin of capital over 3 years, and in another: only a declaration, the global risk profile is distorted.
• Basic 15-step KYC process for legal entities
  At COREDO we often build a multistep process where, regardless of the country, the following mandatory steps are present:
  • company identification (registration documents, articles of association);
  • identification of beneficial owners and the control structure;
  • verification of directors and key controlling persons;
  • analysis of discrepancies between passports and tax residency;
  • proof of address;
  • checks against sanctions, PEPs, negative media;
  • verification of source of funds and sources of income;
  • assessment of the business model and transaction geography;
  • assigning a risk rating;
  • decision: onboard / reject / EDD / additional requests.
• KYT policy and transaction monitoring
  • rules for real-time monitoring of suspicious transactions;
  • trigger logic by countries and counterparties;
  • approach to blocking/holding transactions and requesting documents.
• Requirements for digital compliance and cybersecurity
  • use of digital identification systems and eIDAS (for the EU);
  • requirements for storing KYC files and activity logs;
  • basic cybersecurity standards: client data protection, access control, logging of verifications.
• Role of an independent compliance officer
  • uniform qualification requirements;
  • independent reporting to the Board of Directors;
  • veto power over risky onboardings.

Where local adaptation of KYC is mandatory
Even a perfectly built global standard does not negate the fact that EU KYC requirements, fintech regulation in Asia and the practices of CIS regulators differ.

I see three levels where local adaptation is not just desirable, but critical.

Requirements and timelines

• In a number of EU countries regulators are moving from “simplified verification” to a strict model of full KYC checks for almost all categories of clients.
• Verification timeframes are shortening: what used to take up to 10 days is now expected to be completed within 2–5 days: especially in fintech, so the client does not go to a competitor.
• For payment companies and crypto licenses, local regulators (for example, in Lithuania, Estonia, Cyprus) set separate requirements for the structure of AML/KYC policies, the content of reporting and data formats.

• EU directives, PSD2, eIDAS for payment and fintech companies;
• requirements of local Asian supervisory authorities, aligned with FATF Guidance;
• requirements for machine-readable AML reporting and online monitoring by regulators.

Substance and real presence requirements

• a real office and staff,
• local directors,
• risk management and on-site compliance,
• the volume of operations in the jurisdiction.

• reallocation of functions (risk, AML, IT) between countries;
• justification of why KYC functions are centralized or, conversely, localized;
• the argument for substance in the exact country where you want to obtain a license or a bank account.

Practice of banks and payment partners

• unclear beneficiary structure;
• mismatch between passports and tax residency;
• lack of transparent evidence of source of funds;
• weak group-level KYC policy and absence of local procedures.

KYC vs KYT and the Travel Rule: what’s changed

• implementation of the FATF Travel Rule: transmission of sender and recipient data between VASPs (Virtual Asset Service Providers) and payment institutions;
• real-time monitoring of sender and recipient against sanctions and risk lists;
• use of blockchain analyzers to assess the risk of addresses and transactions.

• restructure internal policy from “one-time KYC at onboarding” to continuous KYT monitoring;
• implement regulatory synchronization between countries: so that transactions passing through the EU and Asia comply with unified rules on data and reporting;
• prepare for online transaction monitoring by regulators and mandatory data exchange between countries.

KYC for corporate clients: structure

• Basic KYC (all jurisdictions)
  • standard set of company and beneficiary documents;
  • minimal screening for adverse factors;
  • initial risk scoring.
• Enhanced KYC / EDD
  • detailed analysis of structure and ultimate control;
  • in-depth verification of source of funds (bank statements, contracts, financial statements);
  • check of corporate history, M&A deals, changes of beneficiaries;
  • monitoring of PEP status and political risks.
• Special scenarios (CBI, high-risk clients)
  For CBI clients and investment migration, international banks and regulators treat them as high risk.
  • prepare a rationale for the client’s economic substance;
  • demonstrate the consistency of passport, residency, and actual center of interests;
  • document the veracity of the source of funds and the reasons for structuring assets through a particular jurisdiction.

Do KYC automation and digital compliance pay off?

• Reduction of onboarding times from 10 to 2–5 days for corporate clients thanks to digital identification systems and automated checklists.
• Reduced burden on compliance departments: some procedures move to automatic screening and machine-readable reporting for regulators.
• Increased trust from banks and partners: mature digital compliance and cybersecurity are already mandatory criteria when selecting partners.

• implementation of digital identification systems and integration with eIDAS for the EU;
• use of solutions for machine-readable AML reporting and automatic report generation;
• implementation of modules for real-time transaction monitoring and sanctions screening;
• building the internal architecture of embedded AML/KYC procedures into an IT or fintech company’s product.

How to avoid bank account freezes

• there is a single group KYC/AML standard, understandable to banks and PSPs;
• local procedures meet the expectations of the regulators of the specific countries;
• the company establishes KYT and Travel Rule processes in advance according to international requirements;
• a set of evidence of source of funds and justification of the group structure is prepared.

• analyzes exactly where the KYC processes did not satisfy the partner;
• refines the KYC policy and client dossiers;
• builds communication with the bank or payment institution, explaining the business model and compliance framework.

Single standard and local adaptation

For an international group it is not enough to “just adapt to the law”. A strategic KYC framework is needed that withstands scrutiny from regulators, banks and partners simultaneously in the EU, Asia and the CIS.

• Define global risk appetite and target markets
  Answer honestly: which clients you are willing to serve and in which jurisdictions this is permissible.
• Build a single group KYC/AML standard
  • policy structure,
  • KYC/KYT processes,
  • requirements for EDD and CBI,
  • digital perimeter and cybersecurity.
• Make local adaptation by country
  • take into account EU requirements, national laws, PSD2, eIDAS, FATF guidance;
  • embed substance and local regulatory expectations;
  • synchronize reporting and data formats.
• Integrate KYC/AML into the product and operations
  especially for fintech, payment companies, crypto services; ensure real-time monitoring and automation of key procedures.
• Regularly review the policy to meet new requirements
  • FATF and the EU update standards,
  • Asian regulators are increasingly aligning with them,
  • by 2026 the list of mandatory KYC and KYT elements will only growwiden.