KYC / KYB Responsibility Matrix
Who verifies, who screens, and who enforces
1. Purpose
Verification, screening, and enforcement on the platform are divided among specialist third-party providers and the platform itself. This document sets out which party is responsible for which function, so that the division of responsibility is explicit and auditable rather than assumed.
Provider names reflect current arrangements and may change as the platform's vendor relationships evolve. The allocation of responsibility by function is the durable part of this document; the named providers are current as of the date above.
2. Individual Investors
| Function | Performed by | Platform's role |
|---|---|---|
| Identity verification (KYC) | Persona (third-party identity verification provider) | Consumes verification outcome; gates platform access on it |
| Sanctions, PEP, and adverse media screening | Persona | Consumes screening outcome on an ongoing basis; acts on confirmed matches |
| Accredited investor verification | Third-party registered broker-dealer, under the broker-dealer verification method recognized by Rule 506(c) | Consumes verification outcome; gates investment on it |
| Ongoing re-screening | Persona | Receives and acts on alerts |
3. Business (Entity) Investors
| Function | Performed by | Platform's role |
|---|---|---|
| Entity verification (KYB) | Persona (third-party identity verification provider) | Consumes verification outcome; gates platform access on it |
| Entity accreditation, including any applicable look-through determination | Third-party registered broker-dealer, via an entity-level verification path | Consumes verification outcome |
| Beneficial owner and control person identification | Captured as part of KYB by the identity verification provider | Uses beneficial-owner data where required by a specific token's rules |
An entity may qualify as accredited in more than one way — including, for some entity types, by reference to the accreditation of its own equity owners. Determining which test applies, and whether it is met, is part of the broker-dealer's entity-level verification and is not separately assessed by the platform.
4. Issuing Organizations
Organization verification is completed before an organization is invited to the platform, and an organization is invited only once that process has concluded successfully.
| Function | Performed by | Platform's role |
|---|---|---|
| Entity verification (KYB) | Persona (third-party identity verification provider) | Conducted before invitation. Receives the verification outcome and proceeds to invite the organization only on success |
| Rule 506(d) bad actor diligence | Bad Actor Questionnaire completed by each covered person, administered by Yieldz outside the platform; Persona sanctions, watchlist, and adverse-media screening as a cross-check | Requires a cleared questionnaire before invitation; acts on disqualifying findings |
| Ongoing re-screening | Persona | Receives and acts on alerts, including suspension where warranted |
5. Documents and Signatures
| Function | Performed by | Platform's role |
|---|---|---|
| Subscription document hosting and templates | Third-party registered broker-dealer | Presents documents to investors and gates purchase on acknowledgment |
| Signature capture | Third-party e-signature provider | Retains a reference sufficient to retrieve signed evidence |
6. Enforcement — Always the Platform
Regardless of which party performs verification or screening, only the platform enforces the outcome across the system. A single eligibility record, consulted by every token and every transaction path, determines whether a given individual or entity may transact at a given moment. No third-party provider has the ability to directly restrict or permit a transaction on-chain — each supplies an input that the platform's eligibility determination consumes.