Chapter 01 of 08
The Offering · Vol. 02 No. 01
The Room · 01
September 2026 · London
Onboarding · 8 September 2026
KYC, the travel rule, and who is actually your customer
Onboarding is not a checkbox on a waitlist. It is a decision about whether the issuer, a CASP, or nobody is forming a business relationship — and which AML, data and travel-rule duties attach. Communications firms should not be in that stack.
The Desk · Operating notes, RCA Pad · London
ICO-intent teams talk about KYC the way they talk about audits: as a badge. KYC is a process owned by a person who is actually forming relationships, collecting identity data, and sometimes moving value. If that person is not you, do not collect the data. If that person is you, do not hide the process inside a growth CRM. If that person is a pad, you have made a pad part of the offering.
Customer · Chapter 01
Who is the customer, in a sentence a lawyer would not laugh at
Users of software, counterparties, purchasers, and “the community” are different people.
Write four lists. Users of the product who never touch a token sale. Professional counterparties — exchanges, market makers, vendors. Purchasers, if any, of the instrument. Everyone in a Discord who thinks they are the first three. The AML, consumer, data-protection and travel-rule consequences attach differently. Mixing the lists is how you KYC a newsletter subscriber and fail to KYC a buyer.
If you are not offering, you may have users and counterparties and no purchasers. That is a clean file. Do not dress users as purchasers to make the community feel included. Inclusion is how you manufacture customers you are not prepared to onboard.
If you do not know who the customer is, you are not ready to collect a passport. You are not ready to skip collecting one either. You are at the map.