Bank & PSP Onboarding Dossier (Bosnia-Based) — Crypto & FinTech Compliance Pack
Banks, PSPs, and acquirers do not reject crypto/fintech projects because of one missing document—they reject them because the risk story is unclear. This service delivers a bank-ready evidence and compliance package for teams operating via Bosnia & Herzegovina (Republika Srpska): KYB/UBO documentation, AML/KYC/sanctions controls, funds-flow diagrams, transaction monitoring logic, vendor due diligence, and a bank-style Q&A narrative that makes your model explainable and verifiable.
The dossier does not guarantee account opening or PSP acceptance (third-party decisions). It is designed to reduce uncertainty and show a mature, auditable compliance posture.
Why banks and PSPs reject (and how the dossier fixes it)
In banking and payments, “risk” is not an opinion—it’s a checklist. When a counterparty can’t verify who you are, how funds move, who holds custody, how you screen customers, and how you detect suspicious activity, the safest decision is “no.”
Unclear funds flow
Banks want to see collections, holding, settlement, refunds, chargebacks, and payouts mapped end-to-end—plus who controls each step.
Weak KYB/UBO evidence
A credible KYB pack includes corporate documents, UBO proof, management roles, source-of-funds narrative, and operational footprint.
Compliance “paper” without operations
Policies must connect to real controls: screening, monitoring, escalation, case handling, recordkeeping, training, and audits.
Who this is for
This dossier is designed for projects that operate through Bosnia & Herzegovina (Republika Srpska) (company, compliance stack, local providers) and need to pass risk review by banks and payment partners—often with global clients, including the US and Canada.
Crypto & crypto-adjacent businesses
- On/off-ramp architectures
- Wallets (custodial or non-custodial, depending on the model)
- OTC/brokerage-like services (model-dependent)
- VCSP/VASP operations requiring bank/PSP credibility
- Corporate crypto treasury operations needing banking evidence
FinTech / payments / merchant services
- Merchant acquiring / payment facilitation (model-dependent)
- High-risk merchant categories with enhanced controls
- Payout platforms and marketplace disbursements
- Subscription billing and cross-border collections
- Payment gateways, aggregation models, PSP integrations
Pre-onboarding stage
Before you apply, we package the evidence so the first risk review is clean and structured.
During onboarding
When you already have a bank/PSP dialogue and deadlines, we respond with bank-style answers and documents.
De-risking / remediation
When accounts are restricted/closed, we build a remediation narrative with improved controls and evidence.
What’s inside the Bank & PSP Onboarding Dossier
The dossier is a structured set of documents and evidence, built around the questions compliance teams actually ask. We adapt it to your model (B2B/B2C, custody exposure, fiat touchpoints, geography, merchant categories).
1) KYB & corporate evidence pack
- Corporate documents, registry extracts, director/shareholder structure
- UBO identification and verification logic (evidence standards)
- Management & governance: roles, approvals, controls, segregation of duties
- Operational footprint: address, local providers, internal responsibilities
- Source of funds (SoF) narrative and supporting proof (as appropriate)
2) Funds-flow diagrams & “who touches what” map
- End-to-end money flow: collection → holding → settlement → payout → refunds
- Role mapping: you vs bank/PSP vs merchants vs customers vs vendors
- Custody/exposure analysis: where value is controlled, who has keys/authority
- Reconciliation logic: how balances match, exceptions are handled, evidence is stored
- Dispute flows: chargebacks, refunds, returns, complaint handling
3) AML/KYC/KYB & sanctions control framework
- AML policy + procedures aligned to your risk profile
- KYC/KYB onboarding flows, risk scoring, ongoing review triggers
- Sanctions screening workflow (e.g., OFAC/EU/UN lists) + escalation rules
- PEP/adverse media approach (if applicable)
- Recordkeeping and audit trail standards
- Suspicious activity workflow: detection → review → decision → documentation
4) Transaction monitoring and operational controls
- Monitoring scenarios (rules/thresholds) based on your activity type
- Case handling: investigations, internal notes, evidence attachments
- Risk controls for high-risk merchants (if relevant): rolling reserves, MCC logic, prohibited categories
- Geo-fencing and restricted jurisdictions policy
- Incident response outline (operational readiness)
- Staff training outline and responsibilities matrix
5) Vendor due diligence pack
- KYC provider, sanctions screening, hosting, custody/exchange vendors (if used)
- Why each vendor is chosen and how they are monitored
- Data security basics and access control responsibilities
- Business continuity assumptions (what happens if vendor fails)
- Contractual risk boundaries and oversight approach
6) Bank-style Q&A dossier
- A structured set of answers to typical bank/PSP compliance questionnaires
- Consistent narrative: model → flows → controls → evidence
- Red-flag prevention: what not to claim, what to clarify, what to evidence
- Prepared responses for enhanced due diligence requests
- Optional: review of your website copy and onboarding forms for compliance risk
The goal is not to “look good.” The goal is to be verifiable: every claim should be supported by documents, workflows, and evidence logs.
Deliverables (structured list)
The dossier can be delivered as a structured folder plus a “master index” document that banks/PSPs can navigate quickly. If your counterparty uses a specific questionnaire format, we adapt to it.
| Module | Documents / artifacts | Common bank/PSP questions it answers |
|---|---|---|
| Corporate & KYB | Corporate docs, structure chart, UBO evidence standards, governance outline, SoF narrative (as applicable). | Who owns the business? Who controls decisions? Where does capital come from? Who are the key persons? |
| Funds flow | Flow diagrams, responsibility matrix, reconciliation logic, refunds/chargebacks/dispute flows. | Where does money go? Who holds funds? How are balances protected? What happens in disputes? |
| AML/KYC/KYB | AML policy, risk assessment, onboarding tiers, UBO checks, ongoing review triggers, recordkeeping. | How do you onboard customers and merchants? How do you assess risk? What evidence do you keep? |
| Sanctions | Sanctions screening workflow, escalation rules, evidence logs, periodic re-screening approach. | How do you prevent sanctioned exposure? What lists do you screen? Who reviews escalations? |
| Monitoring | Monitoring scenarios, thresholds, investigations workflow, case documentation standards. | How do you detect suspicious activity? Who investigates? How do you document decisions? |
| Vendor DD | Vendor list, due diligence notes, oversight logic, security responsibilities, contingency approach. | Who are your key vendors? How do you manage third-party risk? What data/security controls exist? |
| Bank-style Q&A | Questionnaire responses, narrative consistency checks, supporting annexes and evidence. | Can your compliance story be verified quickly? Does it match your actual product and website? |
Process: how we build your dossier
We work fast, but we do not guess. The dossier is built around your real flows and controls, so it remains consistent under scrutiny.
NDA + intake
We sign an NDA, collect a short product and flow description, target markets, volumes, and your current documents (if any). We identify the counterparty type: bank, PSP, acquirer, sponsor, or multiple.
Model mapping (functions & flows)
We map the real activity: custody exposure, fiat touchpoints, merchant types, refunds/chargebacks, geography, and who performs AML obligations across the chain.
Draft controls & evidence pack
We produce the KYB/UBO pack, fund flows, AML/KYC/sanctions framework, monitoring logic, and vendor DD. We add “bank-style” clarity: indexes, annexes, and evidence links.
Q&A alignment and final delivery
We align your story across documents, website statements, and operational reality. Final delivery includes a master index and a clean structure for onboarding submission.
If you already have policies or a compliance stack, we perform a gap analysis first and only rebuild what is needed for counterparties.
What we need from you (typical inputs)
You do not need to be “perfect” to start. Even rough flow sketches are enough—our job is to structure them.
Business & operations
- Short description of your product, customers (B2B/B2C), and monetization
- Target geographies (US/Canada yes/no; global markets)
- Merchant categories and risk profile (if payments/merchant services)
- Expected volumes, average ticket size, payout frequency, chargeback risk
- Refund and dispute handling approach (even if “not built yet”)
Documents & vendors
- Corporate documents (if incorporated), ownership/UBO information
- Any existing AML/KYC policies or onboarding flows
- Vendor list (KYC, sanctions, hosting, custody/exchange, PSP/acquirer) if selected
- Basic security/access control notes (who has access to what)
- Website or draft landing pages (to align claims with controls)
US/Canada note (important)
This dossier is designed to support onboarding with banks/PSPs in a global context and for Bosnia-based operating structures. If you plan to serve US/Canada customers directly (especially retail), additional jurisdiction-specific considerations may apply.
If needed, we can add optional US/Canada nexus guardrails: segmentation, geo-fencing, marketing boundaries, and escalation rules for when local counsel is required.
We do not position Bosnia-based structuring as a substitute for US/Canada licensing obligations where they apply. We focus on evidence, controls, and risk clarity.
FAQ
What is the difference between “policies” and a real onboarding dossier?
Policies alone are rarely enough. A real dossier includes: (1) clear funds-flow diagrams, (2) evidence logs and proof standards, (3) a responsibility matrix across vendors and partners, and (4) bank-style Q&A that is consistent and verifiable.
Can you help if we already got rejected by a bank/PSP?
Yes. We treat this as a remediation project: identify what triggered rejection (flows, merchant risk, custody exposure, missing evidence), rebuild the narrative, strengthen controls, and package evidence in a way risk teams can validate.
Do you guarantee account opening or PSP approval?
No. Third-party decisions cannot be guaranteed. What we provide is a structured, evidence-based package that reduces uncertainty and improves readiness for risk review.
How is confidentiality handled?
Before any work begins, we sign an NDA. We request only what is necessary and can use secure channels for file exchange.
Can this dossier be used together with a Bosnia-based VCSP/VASP setup?
Yes. Many VCSP/VASP projects require banking/PSP relationships to operate. We align the dossier with your Bosnia-based compliance stack and operational controls.
What if we have no compliance stack yet?
Then the dossier becomes your foundation: we create the AML/KYC/sanctions framework, monitoring logic, evidence standards, and operational playbooks—so you can pass onboarding and operate consistently afterwards.
Contact BHL
Send a short description (5–10 sentences): what you do, who your customers/merchants are, whether you touch fiat and/or custody, your target geographies (US/Canada yes/no), and where you are stuck (bank account, PSP, acquiring, merchant account). We’ll confirm scope under NDA and start packaging the dossier.
Disclaimer: This page is for general informational purposes only and does not constitute legal advice, an individualized recommendation, or a public offer. Scope, deliverables, timelines, and fees are confirmed in a signed engagement. Requirements depend on your business model and the expectations of third-party banks/PSPs.