Column customers are responsible for conducting KYC/KYB processes for entity identity verification. You must verify every entity in your platform before any bank accounts, loans, or transfers are created for them. Column will conduct periodic due diligience on your KYC/KYB processes based on compliance policies agreed upon together.

Here's what we expect of our customers at a minimum. Certain use cases may necessitate additional items.

• Bank Secrecy Act / Anti-Money Laundering (BSA / AML): To fulfill regulatory requirements around BSA / AML, you'll be required to perform Know Your Customer / Know Your Business verification on all your customers. There are a number of vendors that can help with this. You'll also have to provide policies documenting your Customer Identification Program (CIP), BSA / AML Compliance and OFAC checks. Column can help you get started with these policies if you do not already have them.
• Customer Application and / or Onboarding: We'll ask you to provide an overview of how you take in customer applications and how you onboard your customers onto your products.
• Know Your Business checks on your business: Column will conduct KYB checks based on information we ask that you provide.