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Accessing the Protocol
In order to interact with the TruFin protocol, a user must first be onboarded and have their wallet placed on a list. The process will check that the potential user meets the KYB/AML thresholds set by the foundation and will be repeated periodically based on our risk assessment (this, at time of writing, would be yearly in most cases). Wallets will then be monitored on an ongoing per-transaction basis for AML / CFT compliance by TRM Labs.
Initially, onboarding will be an intentionally gradual process as we use the launch to battle test the protocol.
Allow-listing enables everyone on the protocol to compete on a level playing field. It both allows access to sources of capital that would otherwise be prohibited from investing and provides additional stability to other users.
The process also enables us to avoid providing access to the protocol from jurisdictions where the product might be prohibited by regulation or law. The currently blocked geographies include the Crimea, Donetsk, or Luhansk regions of Ukraine or the nations of Iran, North Korea, Cuba, Syria, Sudan, or if the User is otherwise subject to economic sanctions or listed as a Specially Designated National by the United States Office of Foreign Asset Control (OFAC). However, TruFin makes no representation that such examples are complete, definitive or accurate.
In order to allow access a User needs to be checked against the compliance requirements set by the protocol. Over time the methods that can be used to do this will grow. Initially, the primary option available is via Quadrata's digital passport.
As a result of this no personal information will be shared with the protocol, the core contributors or other users and the only on-chain record of allow-listing being granted by the process will be a wallet ID being written to the stored list.
As onboarding ramps up it may be that, after signing up for access, application processing is paused and you will be asked for consent to be put onto a waiting list. Once TruFin is able to process further applications you will be notified and you will be asked to continue the process as normal.
Wallets on the allow list will be monitored on an ongoing basis and will be removed if they break the guidelines set up by the foundation. This monitoring takes place both at a wallet level and on an individual basis. Our transaction monitoring is provided by TRM Labs tracking against a risk profile agreed by the foundation. Our allow-list partners provide ongoing monitoring of underlying entities and individuals to ensure, alongside TRM, that Users who would no longer meet onboarding requirements do not remain on the platform.
If a previously allow-listed wallet fails ongoing monitoring checks the funds held will no longer be accessible to the User while an investigation takes place within a 10-day window. If the wallet has breached the protocol's access requirements the funds may be locked indefinitely.
We assess on a range of criteria for KYB and KYC including, but not limited to, real world sanctions and watchlist monitoring, operating jurisdiction, ultimate beneficiary checks for KYB, identity and liveness checks as well as wallet-based sanctions.
If you have been rejected through third-party KYC/B we're happy to help try to resolve things. We're a relatively new protocol so please bear with us via [email protected] for us to assess whether we can help.
The product roadmap leads towards automated onboarding and KYB/KYC solutions for more complex entities. The intention is to add multiple potential options for users going forwards as third-party providers develop their products and the user pool broadens.