AML is a system, not a vendor logo

A screenshot of a KYC tool is not a programme.

Where an issuer or an intermediary is in scope for AML — and that is a legal question — the work is a programme: ownership, risk assessment, policies, onboarding, screening, monitoring, reporting, training, record-keeping. A growth lead buying a SaaS seat is not a programme. A pad that says they “do KYC” is a vendor claim. Put their licence, their jurisdiction, and their actual process in the room, or do not use them.

RCA Pad is not your MLRO. We will not design your AML programme. We will refuse to wire purchaser onboarding through the launch workspace. We will keep the partner map honest about who owns the function.

Who owns onboarding

If the row is empty, do not collect identity data “in case.”

Issuer: You are forming the relationship. You need counsel, a programme, a vendor, a notice, a retention rule.
CASP / platform: They onboard for their service. Their perimeter is not yours. Their failure becomes your fact if they sell your token.
Transfer agent / broker: Traditional rails. Rare in ICO-intent folklore. Real in some US families.
Nobody yet: Not offering. Do not KYC “interest.” Do not store passports for a sale that does not exist.
RCA Pad: Never. Not in the Sprint. Not in a “we can add it.”

Planning a regulated ICO? Same screen as everyone.