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Compliance & VerificationVerification & Readiness

Verification & Readiness

The readiness evaluation is the central decision engine that determines what should happen next for any given investment. Every time an investment's c...

The readiness evaluation is the central decision engine that determines what should happen next for any given investment. Every time an investment's circumstances change (SPV opens, identity gets verified, bank account registers), the system re-evaluates and decides the next step automatically.

The Compliance Policy

The compliance policy is the single source of truth for all compliance-related decisions. It controls two independent concerns:

  1. Verification blocking -- whether identity or entity verification must pass before payment can be dispatched
  2. Background KYC -- whether KYC is submitted in the background for all investors when they commit an investment

Verification Blocking Modes

Verification blocking has three modes. The current mode is shown in the admin dashboard.

ModeBank pull blocked?Wire blocked?External (IRA/DAF) blocked?Verification visible to investor?
Skip (default)NoNoNoNo
Bank Pull OnlyYesNoNoYes (bank pull investments only)
AllYesYesNoYes (bank pull + wire)

Important: External (IRA/DAF) investments always bypass verification regardless of mode -- the custodian or sponsor handles compliance. Wire is NOT unconditionally bypassed; its blocking behavior depends on the mode.

Background KYC

Background KYC runs as a fire-and-forget process. When it is enabled, KYC is submitted to the compliance provider in the background for every investor at the moment they commit an investment.

  • It runs for all investors (individuals and entities)
  • It never blocks the investment or payment flow
  • It is not visible to the investor
  • Results are recorded against the investor's verification history and in the audit trail
  • Pre-V2 investors who were grandfathered in (carried over as already Approved) are skipped

Background KYC is independent of the verification blocking mode. Even when blocking is set to Skip, background KYC still fires if it is enabled. See the Background KYC Monitoring playbook for how to monitor results.

How It Works

When an investment is evaluated, the system checks a series of conditions in order. The compliance policy determines whether verification is checked at all:

Flow Comparison by Mode

When verification blocks (Bank Pull Only or All modes):

SPV open → check verification → check bank → dispatch payment

When verification skips (Skip mode, or external investments in any mode):

SPV open → check bank → dispatch payment
(verification entirely skipped in readiness evaluation)

All Possible Outcomes

DecisionMeaningWhat's NeededWhen Applicable
FundedInvestment is fully fundedNothing -- it's completeAlways
HoldWaiting for SPV to be in the right stateSPV needs to be opened (or investment needs attention if SPV is cancelled)Always
Submit KYCIdentity verification needs to be submittedSystem submits automaticallyOnly when verification blocks payment
Submit KYBEntity verification needs to be submittedSystem submits automaticallyOnly when verification blocks payment
Await VerificationVerification submitted, waiting for resultWait -- usually resolves in minutesOnly when verification blocks payment
RemediateVerification needs additional information from investorInvestor needs to provide info. Admin may need to assist. See Document RemediationOnly when verification blocks payment
Register BankBank account needs to be registered with payment providerSystem handles automaticallyAlways (ACH investments)
Dispatch ACHEverything ready -- initiate bank pullSystem initiates automaticallyAlways (ACH investments)
Dispatch WireEverything ready -- send wire instructionsSystem creates expected payment and notifies investorAlways (wire investments)
Dispatch IRAEverything ready -- create custodian wireSystem creates expected paymentAlways (IRA investments)
Dispatch DAFEverything ready -- initiate DAF transferSystem handles automaticallyAlways (DAF investments)
Await PaymentPayment already in progressWait for payment to completeAlways
BlockedCannot proceedAdmin intervention needed -- check the reasonOnly when verification blocks payment

Diagnosing Stuck Investments

If an investment has been in "committed" status for longer than expected, use the readiness evaluation to understand why:

Common Blockers

  1. "SPV Draft" -- The SPV hasn't been opened yet. The investment is waiting for the deal to go live.

    • Fix: Open the SPV when ready.
  2. "KYC Pending" -- Identity verification has been submitted but hasn't returned a result. Note: This only applies when the verification blocking mode is Bank Pull Only or All. In Skip mode, verification never blocks investments.

    • Fix: Usually resolves automatically within minutes. If it's been hours, there may be a provider issue.
  3. "KYC Needs Info" -- The compliance provider needs additional documentation from the investor. Only applies when verification blocking is active.

  4. "KYC Rejected" -- Identity verification failed. Only applies when verification blocking is active.

  5. "Bank Not Registered" -- The investor's bank account hasn't been registered with the payment provider yet.

    • Fix: Usually resolves automatically. If stuck, try the "Register with Provider" button on the bank account page in admin. Once registration succeeds, the system will automatically re-evaluate the investment and dispatch payment.
  6. "Bank Registration Failed" -- Bank registration with the payment provider failed.

    • Fix: Try the "Register with Provider" button on the bank account's admin page to retry. If it succeeds, the system will automatically advance any waiting investments. If it keeps failing, the investor may need to re-link their bank account.
  7. "Payment In Flight" -- A payment has already been initiated and is being processed.

    • Fix: Wait for the payment to complete (or check if it's failed/stuck).

What Admins Should Know

  • Verification blocking is configurable -- the compliance policy controls whether verification is required before payment dispatch. The current mode is Skip (default), meaning verification never blocks investments. Check the admin dashboard to see the current configuration.
  • Background KYC runs independently -- even when verification blocking is off, background KYC still fires for all investors on investment commit (when background KYC is enabled). Monitor results via the Background KYC Monitoring playbook.
  • The system re-evaluates automatically -- whenever something changes (SPV opens, identity approved, bank account registered, payment completed), the system re-runs the evaluation and takes the next step.
  • You rarely need to intervene -- the vast majority of investments flow through the evaluation automatically.
  • "Blocked" means action needed -- this is the one status where the system can't proceed on its own. Check the reason and take appropriate action. Note: "Blocked" due to verification only occurs when blocking mode is active.
  • External investments always bypass verification -- IRA/DAF investments go straight from SPV check to payment dispatch regardless of the verification blocking mode.
  • The audit trail shows evaluation results -- if you need to understand why the system took (or didn't take) a specific action, check the audit trail for the investment.
  • Use "Re-evaluate & Dispatch" as a recovery tool -- if an investment appears stuck after a manual fix (e.g., retrying a bank registration, resolving a verification issue), use the "Re-evaluate & Dispatch" button on the investment page. It will check the current state and take the next appropriate action. See the Stuck Investment playbook for more detail.