Prepared for BaaS partner & sponsor bank due diligence

SyncroFi Compliance & Flow-of-Funds Portal

This portal documents Softsyncron Limited’s architecture, fund-flow controls, and KYC/AML program for review by prospective Banking-as-a-Service partners, sponsor banks, and regulatory counterparties evaluating SyncroFi for partnership.

System Architecture

Flow of funds

Every dollar disbursed to a customer, or as platform revenue, is a dollar that has already settled and been reconciled in the immutable ledger. Click a stage for detail.

Stage 1 of 8

Client payment initiated

A client pays the SyncroFi user's dedicated virtual account routing details (ACH, SEPA, or SWIFT) exactly as they would any local bank account.

No corporate float or credit extension occurs at this stage.

Compliance Program

KYC / KYB architecture matrix

Every account is verified and continuously monitored through a layered stack of third-party and internal controls before funds can move.

Check Type	Vendor / Method	Trigger Point	Data Captured	Outcome
Document Verification	Sumsub (primary) / Onfido (fallback)	Onboarding, Step 3	Government ID, passport, MRZ/NFC data	Pass / Manual Review / Reject
Biometric Liveness	Sumsub Liveness 3D	Onboarding, Step 3	Selfie video, facial landmarks	Liveness confirmed / Spoof detected
Sanctions & PEP Screening	Sumsub AML (OFAC, UN, EU, HMT lists)	Onboarding + daily batch re-screen + per-payout beneficiary	Full name, DOB, nationality, beneficiary details	Clear / Potential match escalation
AML Transaction Monitoring	Internal rules engine	Real-time, every transaction	Amount, velocity, counterparties, corridor risk	Auto-clear / Flag for review / Freeze
Device & IP Risk Scoring	Sumsub Device Fingerprint	Login, onboarding, payout initiation	Device ID, IP geolocation, VPN/proxy signals	Risk score 0–100
Periodic Re-verification	Sumsub scheduled re-KYC	Every 12 months or risk-triggered	Refreshed document + liveness	Re-verified / Account restricted

Velocity limits by risk tier

New account (0–30 days)

Cap: $2,000 / mo equivalent

$500 per transaction

Standard (clean 30-day history)

Cap: $25,000 / mo equivalent

$10,000 per transaction

Enhanced (EDD approved)

Cap: $150,000 / mo equivalent

$50,000 per transaction

Sample webhook payload — vendor to SyncroFi

{
  "applicantId": "usr_8f21ac",
  "type": "applicantReviewed",
  "reviewResult": {
    "reviewAnswer": "GREEN",
    "moderationComment": null
  },
  "sanctionsScreening": {
    "status": "clear",
    "listsChecked": ["OFAC_SDN", "UN", "EU", "HMT"]
  },
  "livenessCheck": "PASSED",
  "riskScore": 12,
  "timestamp": "2026-08-10T09:14:22Z"
}

Legal Structure

Regulatory & legal framework overview

SyncroFi is operated under an EMD Agent / Authorized Delegate model — Softsyncron Limited acts on behalf of, and under the supervision of, its licensed banking and BaaS principals.

Regulator

Applicable financial services regulator(s) by jurisdiction

Licensed Principal

Sponsor bank / licensed EMI (e.g. Lead Bank, N.A., ClearBank Ltd) or BaaS provider

Softsyncron Limited

Authorized Agent / Delegate of the licensed principal — operates SyncroFi

SyncroFi customers

Freelancers, digital nomads, and remote workers

Agent, not principal

Softsyncron Limited operates as an authorized agent / delegate of its licensed banking and BaaS principals. Softsyncron does not itself hold a banking or e-money license and does not claim to.

Segregated FBO safeguarding

Customer funds are held in pooled "for benefit of" accounts at the principal's licensed institution, fully segregated from Softsyncron Limited's corporate assets and never commingled.

No float, no credit risk

Under the settle-first model, Softsyncron Limited never advances funds or extends credit — every payout is funded by the customer's own already-settled balance, eliminating principal counterparty exposure.

Principal oversight & audit rights

The licensed principal retains full audit, reporting, and termination rights over the agent relationship, consistent with standard authorized-agent / appointed-representative frameworks.

This overview is provided for partner and regulatory due diligence purposes and does not constitute a legal opinion. Softsyncron Limited’s specific licensing posture, permissible activities, and agent/delegate arrangements are governed by the definitive agreements executed with each licensed principal and are subject to review by qualified legal and compliance counsel in each operating jurisdiction.