How to do an Initial Coin Offering (Part 1)
Collin Thompson

Note. This is not legal or investment advice. Only my personal views and does represent any employer, investor or partner.

With regards to KYC, based on our experience, there is no magic wand for this. You really need to be doing as much as you can to prove you do ‘Know Your Customer’ and what’s required for this varies from country to country and regulator to regulator.

Always lean towards the safe side. It can be tempting to allow that massive purchase/trade, but it could be the one that makes the whole thing come undone and land everyone in hot water.

Within reason, collect as much information as you can about your investors (or whatever you refer to them as) and make sure you’re checking them against a screening database that covers:

Anti Money Laundering (AML)

Counter-Terrorist Financing (CTF)

Pollitcally Exposed Persons (PEP)

Sanctions lists etc.

Something that doesn't get mentioned often is the incoming CRS rules. This is similar to FATCA (which is based around the reporting of tax affairs for US citizens overseas) but will apply to many more countries required to report on foreign citizens and their assets/investments. It will take a while to implement (as FATCA did) but once it’s in place, you’ll need to be reporting on who your investors are, if they are not from the country your company is incorporated. This will create a lot of headaches if you don’t have good records and you won’t be able to escape your obligations.

If you want to roll the dice (bad idea) then do some basic KYC at the start, and later, if required, enhance it and ask for more information, documents etc. Banks will often go back though their records of existing customers and ask for additional information where required should regulations change or they are tightening their AML policies.

If you need help with KYC for your ICO (or however you will refer to it), chat with us here.