Gates and suitability
Some answers end an application; others decide what the customer may buy. KYC Core applies the gates the moment an application is submitted, and collects the suitability facts the licence profile requires before any service opens.
Who does it: the system applies the gates; the applicant answers the suitability questions; officers decide what is held, in CDD Core.
Gates at submission
Section titled “Gates at submission”| Gate | What it checks | Outcome |
|---|---|---|
| State authority | AMLO lists FREEZE-04 (UN) and FREEZE-05 (Thailand), HR-03 where it is in the institution’s obligations, and sanctioned countries | Refused at once. No scoring, no override. |
| Institution policy | The institution’s external sanctions list | Held. A maker confirms or clears the match in writing and a checker signs. Confirmed → refused; cleared → the application continues, with the reason on record. |
| Prohibited customer list | People the institution will not accept, matched on identity number | Refused. Applies to new applicants only. |
| Policy switches | Applicants under 20, FATCA not completed, a third-party beneficial owner | Refused where the institution has switched the rule on. |
When a person is on an AMLO list and on another list, the AMLO outcome applies; the other match is kept as corroboration. Every refusal shows the same neutral sentence.
DA Dealer edition — mule tiers and the pattern gate
Section titled “DA Dealer edition — mule tiers and the pattern gate”- Agency mule-tier lists. The black, dark-grey, light-grey and dark-brown tiers refuse the application. The light-brown tier goes to EDD before a higher withdrawal class can be granted.
- Suspicious-pattern gate. An application that matches a mule-account pattern is refused outright — no officer hold — and the applicant goes on the institution’s internal blacklist, matched on identity number, device, phone or e-mail. The blacklist is reviewed by the risk management committee in periodic rounds.
- What the gate reads: the IP address and country at each identity step, a device identifier at account opening, the e-mail and employer in comparable form, and the date of birth.
Suitability
Section titled “Suitability”- The applicant answers the suitability questionnaire. The system computes the score and the risk level (1 to 5), and the matching mandate.
- The applicant takes the knowledge assessment. Supporting evidence — a degree, a qualification, a work certificate — may be skipped; the officer uses judgement.
- The investor type is computed from the income range given (its lower end) until an officer approves the actual figures.
An officer records and a checker approves the assessment, the suitability answers and the financial figures on the suitability tab of the customer file.
DA Dealer edition — before service opens
Section titled “DA Dealer edition — before service opens”A dealer customer has four facts on record before trading opens: investor class (declared by the customer, confirmed by an officer), DA suitability, the knowledge test from a versioned question bank, and wallet registration with proof of ownership. An application can be approved before all four are in; the account then stands as “approved, service not opened”, with no leg open.
What the system does or refuses
Section titled “What the system does or refuses”- No override button exists for a state-authority match.
- Approval is refused while a risk acceptance form is missing for a product or portfolio above the customer’s suitability level.
- A failed knowledge assessment sends a ban on complex products to the order system; a pass sends the release.
- Prescribed warnings are shown in the regulator’s words, from a controlled text set.