Glossary

The language of
high-risk banking.

113+ terms covering licences, regulators, AML/KYC, payment processing, crypto, corporate structures, and trade finance. No jargon, no fluff.

§01 · Licences & regulators

Licences & regulators.

The agencies that licence high-risk operators and the international bodies whose rules banks enforce.

14 terms

MGAMalta Gaming Authority
The MGA is Malta's gambling regulator and the gold-standard licence for European iGaming operators. An MGA licence opens doors to most EU-licensed banks and EMIs that engage with iGaming, and is the benchmark most banking partners reference when evaluating licensed gambling clients.
UKGCUK Gambling Commission
The UKGC regulates all gambling activity in Great Britain, from online casinos to lotteries. A UKGC licence is one of the most demanding in the world and is required to accept UK-resident players, with strict rules on marketing, affordability checks, and player protection.
Related:MGA,FCA
Curaçao eGaming
Curaçao eGaming offers the cheapest and fastest-issued iGaming licence, historically issued under four master licences. Following the 2024 LOK reform, licences are now issued directly by the new Curaçao Gaming Authority (CGA), tightening AML and player-protection requirements.
Kahnawake Gaming Commission
A First Nations gambling regulator based in the Kahnawake Mohawk territory in Quebec, Canada, operating since 1999. It licences online casinos, poker rooms, and sportsbooks aimed primarily at North American markets where US-state-level licensing is impractical.
CySECCyprus Securities and Exchange Commission
CySEC regulates investment firms, forex brokers, and crypto-asset providers in Cyprus. It is one of the most popular EU jurisdictions for licensing forex and CFD brokers due to relatively accessible capital requirements and EU-passporting rights under MiFID II.
Related:FCA,ASIC
FCAFinancial Conduct Authority
The FCA is the UK's financial conduct regulator overseeing banks, EMIs, payment institutions, and crypto-asset firms. FCA authorisation is a high bar and is widely respected internationally, but the FCA has tightened its stance on high-risk verticals including crypto since 2020.
Related:UKGC,PSD2
ASICAustralian Securities and Investments Commission
ASIC regulates financial services, markets, and corporations in Australia. ASIC-licensed forex brokers were historically attractive due to flexible leverage rules, though leverage caps introduced in 2021 brought Australia closer to EU and UK norms.
Related:CySEC,FCA
FINMASwiss Financial Market Supervisory Authority
FINMA is the Swiss financial regulator overseeing banks, insurers, and crypto-asset firms. Switzerland's FINMA-supervised crypto banks (e.g., SEBA, Sygnum) are among the few globally that openly bank licensed crypto businesses, making FINMA highly relevant to crypto founders.
Related:MAS,FCA
MASMonetary Authority of Singapore
MAS is Singapore's central bank and integrated financial regulator, also responsible for licensing payment service providers and crypto firms under the Payment Services Act. A MAS Major Payment Institution licence is highly respected and a strong signal for Asian banking partners.
Related:FINMA,VASP
FATFFinancial Action Task Force
The FATF is the intergovernmental body that sets global AML and CFT standards. Its 40 Recommendations are not law but are implemented domestically by virtually every major jurisdiction, and its grey/blacklists directly affect which jurisdictions banks will engage with.
FinCENUS Financial Crimes Enforcement Network
FinCEN is the bureau of the US Treasury responsible for AML enforcement and collecting suspicious activity data. US-touching businesses, including crypto MSBs and payment firms, must register with FinCEN and file SARs, making it a critical regulator for any USD-denominated activity.
Related:OFAC,MSB,SAR
OFACUS Office of Foreign Assets Control
OFAC administers and enforces US economic and trade sanctions, including the SDN list. Even non-US banks routinely screen against OFAC lists because correspondent USD clearing exposes them to US jurisdiction, making OFAC compliance effectively global.
CIMACayman Islands Monetary Authority
CIMA regulates banking, securities, insurance, and trust services in the Cayman Islands. While Cayman is a major offshore fund domicile, CIMA-licensed banks have become more selective post-CRS and FATCA, and Cayman remains a frequently scrutinised jurisdiction.
FSA Seychelles / IFSC Belize / FSC BVI
Three commonly used offshore financial regulators: the FSA Seychelles licences forex and securities firms cheaply and quickly; the IFSC Belize licences forex brokers and money lenders with light-touch supervision; the FSC BVI regulates funds and corporate services in the British Virgin Islands. All three are popular for cost reasons but increasingly difficult to bank.

§02 · AML / KYC / Compliance

AML / KYC / Compliance.

The vocabulary banks use to describe how they identify customers, screen for risk, and report suspicious activity.

16 terms

KYCKnow Your Customer
KYC is the process by which financial institutions verify the identity of individual customers, typically using passport, proof of address, and selfie checks. It is the bedrock of AML compliance and the first hurdle any new account opening must clear.
Related:KYB,CDD,EDD
KYBKnow Your Business
KYB is the corporate equivalent of KYC: verifying a legal entity's registration, structure, directors, and beneficial owners. For high-risk verticals, KYB onboarding routinely takes 4–12 weeks and requires apostilled corporate documents, licences, and source-of-funds evidence.
AMLAnti-Money Laundering
AML is the framework of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. Banks operationalise AML through KYC, transaction monitoring, sanctions screening, and SAR filing, all overseen by an MLRO.
Related:CFT,CDD,FATF
CFTCounter-Financing of Terrorism
CFT comprises laws and controls designed to prevent funds from reaching terrorist organisations or financing terrorist acts. CFT is almost always paired with AML in regulation (often as AML/CFT) and is enforced via sanctions screening, transaction monitoring, and reporting obligations.
CDDCustomer Due Diligence
CDD is the standard set of checks performed on every customer at onboarding and periodically thereafter, including identity verification, beneficial ownership, and risk profiling. It is the baseline level of scrutiny required by AML regulation for low-risk relationships.
Related:EDD,KYC,KYB
EDDEnhanced Due Diligence
EDD is a heightened level of scrutiny applied to high-risk customers, including PEPs, high-net-worth individuals, and businesses in sectors like iGaming, crypto, and adult. EDD typically requires source-of-funds and source-of-wealth evidence, ongoing monitoring, and senior management approval.
MLROMoney Laundering Reporting Officer
The MLRO is the designated officer at a regulated firm responsible for AML compliance, including reviewing internal suspicious activity alerts and filing SARs with the FIU. Most jurisdictions require licensed PSPs, EMIs, and crypto firms to appoint an MLRO with personal accountability.
Related:AML,SAR,STR
SARSuspicious Activity Report
A SAR is a confidential report filed by a financial institution with its national FIU when it suspects money laundering, fraud, or other financial crime. Filing a SAR does not require proof, only reasonable suspicion, and tipping off the customer is itself a criminal offence.
Related:STR,MLRO,FinCEN
STRSuspicious Transaction Report
STR is the term used in many non-US jurisdictions for what the US calls a SAR: a regulator-mandated report flagging a specific transaction or pattern as potentially illicit. Functionally identical to a SAR, with the same confidentiality and tipping-off rules.
Related:SAR,MLRO
PEPPolitically Exposed Person
A PEP is an individual entrusted with prominent public functions (heads of state, ministers, judges, senior military, state-owned enterprise executives) plus their immediate family and close associates. PEP status automatically triggers EDD and ongoing enhanced monitoring throughout the banking relationship.
UBOUltimate Beneficial Owner
The UBO is the natural person who ultimately owns or controls a legal entity, typically defined as holding 25% or more of shares or voting rights. Banks require UBO disclosure during KYB and most jurisdictions now maintain UBO registries to combat shell-company abuse.
Source of FundsSoF
Source of Funds refers to the origin of the specific money being deposited or transacted, evidenced by salary slips, sale contracts, dividend statements, or invoices. Banks require SoF documentation for any unusual or large transaction, especially in high-risk verticals.
Source of WealthSoW
Source of Wealth refers to the origin of a customer's overall net worth, not just the funds in question, and is typically requested for HNW individuals, PEPs, and EDD cases. Acceptable evidence includes business sale documents, inheritance records, multi-year tax returns, or audited financials.
Travel Rule
The FATF Travel Rule requires VASPs to share originator and beneficiary information for crypto transfers above a threshold (typically $1,000 or €1,000). Implementation varies by jurisdiction and creates significant operational complexity for crypto exchanges and custodians processing cross-border transfers.
Related:VASP,FATF,AML
FATF Greylist / Blacklist
The FATF greylist names jurisdictions with strategic AML deficiencies under increased monitoring, while the blacklist names those subject to active countermeasures. Greylisted jurisdictions face heightened scrutiny from correspondent banks; blacklisted ones (currently North Korea, Iran, Myanmar) are effectively cut off from the global banking system.
Sanctions screening
Sanctions screening is the automated comparison of customer and transaction data against sanctions lists (OFAC SDN, EU consolidated, UK OFSI, UN). Banks screen at onboarding and continuously, and a positive match typically freezes the account pending investigation, with reporting obligations to the relevant authority.
Related:OFAC,PEP,AML

§03 · Banking infrastructure & rails

Banking infrastructure & rails.

The plumbing through which money actually moves between banks, currencies, and countries.

9 terms

IBANInternational Bank Account Number
An IBAN is a standardised international bank account format used across Europe and many other regions, encoding country, bank, and account number into a single string. IBANs enable straight-through processing on SEPA and SWIFT and are the default identifier for euro-area transfers.
SWIFT / BIC
SWIFT is the global messaging network used by banks to send payment instructions, identified by an 8- or 11-character BIC code. SWIFT is not a settlement system; actual money movement happens via correspondent banking, which is why SWIFT transfers can take 1–5 days and accumulate fees.
SEPASingle Euro Payments Area
SEPA is the EU-wide euro payments area covering 36 countries, enabling cheap or free euro transfers between member-state IBANs. SEPA Instant settles within seconds 24/7, while SEPA Credit Transfer settles within one business day, and SEPA membership is a major selling point for any EU-licensed EMI.
ACHAutomated Clearing House
ACH is the US batch-processing payment network for domestic USD transfers, used for payroll, bill payments, and B2B settlements. ACH is cheap (often a few cents per transfer) but slow, with same-day, next-day, and two-day settlement tiers, and it is reversible for up to 60 days for consumer transactions.
CHAPSClearing House Automated Payment System
CHAPS is the UK's same-day high-value GBP payment system, used primarily for property purchases and large interbank settlements. Unlike Faster Payments there is no transaction cap, but each CHAPS payment typically costs £20–£35 to the sender.
Faster Payments / FPS
Faster Payments is the UK's real-time GBP payment scheme, settling within seconds 24/7 with a per-transaction limit of £1 million (raised from £250k in 2022). Most UK fintechs and EMIs offer FPS as standard, and it is the default rail for retail and small-business GBP transfers.
Related:CHAPS,SEPA
Correspondent banking
Correspondent banking is the arrangement by which one bank holds an account with another (usually in a different country) to facilitate cross-border payments and FX. The number of correspondent relationships has shrunk dramatically since 2010 due to derisking, making it harder for high-risk businesses to send and receive international wires.
Nostro / Vostro account
A nostro account is "our account with you" held by a domestic bank at a foreign bank, while a vostro account is "your account with us" held by a foreign bank at a domestic bank. The two terms describe the same account from opposite sides of a correspondent banking relationship.
Multi-currency account
A multi-currency account holds balances in several currencies under a single account or set of linked sub-accounts. Common at EMIs and challenger banks, multi-currency accounts let high-risk businesses receive payments and hold reserves without forced conversion, often with separate IBANs per currency.
Related:IBAN,EMI

§04 · Payment processing & merchant services

Payment processing & merchant services.

Everything between the customer's card and your bank account, plus the metrics and codes that decide whether a merchant gets banked.

20 terms

PSPPayment Service Provider
A PSP is a third-party company that processes card and alternative payments on behalf of merchants, typically aggregating multiple acquirers, payment methods, and risk tools. High-risk PSPs specialise in iGaming, adult, forex, and crypto and charge significantly higher fees and reserves than standard PSPs.
MSBMoney Service Business
An MSB is the US regulatory category for businesses transmitting money, exchanging currency, or dealing in crypto, requiring FinCEN registration and state-by-state money transmitter licences. MSBs face high banking friction in the US because banks see them as introducing third-party AML risk into their book.
Related:EMI,PI,FinCEN
EMIElectronic Money Institution
An EMI is an EU/UK-licensed institution authorised to issue e-money and provide payment services without a full banking licence. EMIs (Wise, Revolut Business, ClearJunction, etc.) are the de facto banking solution for many high-risk businesses that cannot get a traditional bank account but need IBANs and SEPA access.
PIPayment Institution
A PI is an EU/UK-licensed entity authorised to provide payment services such as money remittance, acquiring, and account information services, but unlike an EMI it cannot issue e-money or hold customer balances long-term. PIs are common for acquiring-only and remittance-only business models.
Related:EMI,PSD2
MCCMerchant Category Code
An MCC is a four-digit code assigned by Visa and Mastercard to classify a merchant's line of business. The MCC drives interchange rates, chargeback risk classification, and whether issuers will allow transactions, making MCC selection a critical setup decision for high-risk merchants.
MCC 7995
MCC 7995 covers betting, lottery, casino gaming, and online gambling. Most issuing banks block MCC 7995 by default for cardholders in restricted jurisdictions (US, parts of Asia), and acquiring under this MCC requires a licensed gambling operator and a high-risk acquirer that explicitly supports gaming.
Related:MCC,MGA,UKGC
MCC 5967
MCC 5967 covers direct marketing of inbound teleservices, in practice used for adult chat, cam sites, and adult content subscriptions. Adult MCCs face the highest chargeback rates in card processing, mandatory adult-content registration with Visa/Mastercard, and very limited acquirer choice.
MCC 6051
MCC 6051 covers quasi-cash transactions including money orders, foreign currency, and crypto purchases. Many issuers treat MCC 6051 as a cash advance, applying higher fees and immediate interest, and several jurisdictions and issuers block it entirely for retail crypto purchases.
Related:MCC,VASP
Chargeback
A chargeback is a forced reversal of a card transaction, initiated by the cardholder via their issuing bank, typically for unauthorised use, non-delivery, or dispute over goods. Each chargeback costs the merchant the transaction amount plus a fee of $15–$50, and excessive chargebacks lead to processor termination.
Chargeback ratio
The percentage of card transactions disputed by customers and reversed. Visa and Mastercard flag merchants as high-risk above 0.9% and may terminate above 1.8%, which is the threshold most card-acquiring banks use when deciding whether to retain a merchant account.
Rolling reserve
A rolling reserve is a percentage of a merchant's sales (typically 5–15%) held by the acquirer for a defined rolling period (typically 90–180 days) to cover chargebacks and refunds. Rolling reserves are standard for high-risk merchants and substantially affect cashflow, especially in the first year of processing.
Static reserve
A static reserve is a fixed sum held by the acquirer for the duration of the merchant relationship, often required up-front or built up from initial sales. Unlike a rolling reserve, the static portion does not release back to the merchant until account closure and full chargeback runoff.
Refund ratio / dispute ratio
The refund ratio is the percentage of transactions refunded by the merchant directly, while the dispute ratio includes chargebacks. Visa's Dispute Monitoring Program escalates merchants above 0.9% disputes, and high refund ratios alone can trigger acquirer review even without chargebacks.
3D Secure (3DS)
3D Secure is the card-network protocol that adds an authentication step (SMS code, biometric, app prompt) to online card transactions, shifting liability for fraud from the merchant to the issuer when authenticated. 3DS2 is now mandatory in the EU under PSD2 SCA and substantially reduces fraud-related chargebacks.
Card acquiring
Card acquiring is the service of accepting card payments on behalf of a merchant, performed by an acquirer that holds the merchant account and settles funds. High-risk acquiring is a specialist niche (Worldpay, Trust Payments, Praxis, etc.) with stricter underwriting, higher fees, and mandatory reserves.
Card issuing
Card issuing is the business of providing payment cards (debit, credit, prepaid) to end users, performed by an issuer (a bank or fintech via a sponsor bank/BIN sponsor). Modern issuing platforms (Marqeta, Stripe Issuing, Enfuce) let fintechs launch branded cards without obtaining their own BIN.
PCI DSS
PCI DSS (Payment Card Industry Data Security Standard) is the mandatory security framework for any entity that stores, processes, or transmits cardholder data. Compliance is tiered by transaction volume (Level 1 = >6M annually) and is enforced by acquirers; non-compliance can void merchant agreements and result in heavy fines.
APMAlternative Payment Methods
APMs are non-card payment methods including bank transfers, e-wallets (PayPal, Skrill, Neteller), open-banking pay-by-bank, vouchers, and crypto. APMs are critical for high-risk verticals where card acceptance is restricted or chargeback risk is high, and they often have lower fees and zero chargebacks.
MDRMerchant Discount Rate
The MDR is the total fee a merchant pays to its acquirer per card transaction, expressed as a percentage plus optional fixed component. MDR comprises interchange (paid to issuer), scheme fees (paid to Visa/MC), and acquirer margin; high-risk MDRs typically run 3.5–6% versus 1–2% for standard merchants.
Interchange fee
The interchange fee is the portion of MDR paid by the acquirer to the cardholder's issuing bank for each transaction. Interchange is set by the card networks and capped in some jurisdictions (EU caps consumer debit at 0.2% and consumer credit at 0.3%), but uncapped on commercial cards and cross-border transactions.

§05 · Crypto-specific

Crypto-specific.

The licences, regulations, and operational concepts unique to crypto businesses seeking banking.

7 terms

VASPVirtual Asset Service Provider
VASP is the FATF-defined category covering exchanges, custodians, and other businesses providing virtual-asset services. VASP registration or licensing is now required in most major jurisdictions, and most banks will only engage with crypto businesses that hold a recognised VASP authorisation.
CASPCrypto-Asset Service Provider
CASP is the EU-specific term used in MiCA for a regulated crypto-asset service provider, broadly equivalent to VASP but with EU-harmonised authorisation. From late 2024, CASPs need a single MiCA authorisation that passports across all 27 EU member states.
Related:VASP,MiCA
MiCAMarkets in Crypto-Assets regulation
MiCA is the EU regulation that creates a unified regime for crypto-asset issuers and CASPs, fully applicable from 30 December 2024. MiCA brings legal clarity, stablecoin reserve rules, and EU-wide passporting, and is expected to make EU-licensed crypto firms substantially more bankable than before.
Related:CASP,VASP
FIUFinancial Intelligence Unit
An FIU is the national agency that receives, analyses, and disseminates SARs and STRs from regulated entities, examples including FinCEN (US), the NCA (UK), TRACFIN (France), and Rosfinmonitoring (Russia). FIUs are members of the Egmont Group, which facilitates cross-border information sharing on financial crime.
Related:SAR,STR,MLRO
On-ramp / Off-ramp
An on-ramp converts fiat to crypto (typically via card or bank transfer); an off-ramp converts crypto back to fiat. Reliable fiat ramps are the single biggest banking pain point for crypto businesses, and most exchanges contract with multiple providers to maintain redundancy.
Custodial vs non-custodial
A custodial service holds users' private keys and crypto on their behalf (Coinbase, Binance), while a non-custodial service lets users retain their own keys (MetaMask, Ledger). Custodial services face the heaviest regulatory burden including capital, audit, and segregated-account requirements, while non-custodial services typically fall outside VASP scope.
Related:VASP,CASP
Chain analytics
Chain analytics tools (Chainalysis, Elliptic, TRM Labs) trace blockchain addresses to known entities and risk-score transactions for AML compliance. Banks and licensed VASPs use chain analytics to screen incoming and outgoing crypto, blocking flows associated with sanctions, mixers, darknet markets, or stolen funds.

§06 · Account structures

Account structures.

Different ways of structuring corporate, client, and beneficiary money inside the banking system.

5 terms

Segregated client account
A segregated client account holds each customer's funds separately in a dedicated bank account or sub-account, ring-fenced from the operator's own money. Required for licensed iGaming operators (e.g., MGA, UKGC) and many investment firms to protect player or client funds in case of operator insolvency.
Omnibus account
An omnibus account pools client funds from many customers in a single bank account, with the operator maintaining internal ledgers tracking each customer's balance. Cheaper and operationally simpler than segregated accounts, omnibus structures rely heavily on the operator's reconciliation discipline and are accepted in fewer regulated contexts.
Escrow account
An escrow account holds funds on behalf of two parties pending fulfilment of conditions in an underlying contract, controlled by a neutral third-party escrow agent. Common in M&A, real estate, and high-value B2B transactions, escrow accounts reduce counterparty risk by giving each side certainty over fund release.
Trust account
A trust account is held by a trustee on behalf of one or more beneficiaries under the terms of a trust deed, with legal title separated from beneficial interest. Used in private wealth, estate planning, and fund administration, trust accounts offer asset protection but require careful structuring to satisfy bank KYC on the trustee, settlor, and beneficiaries.
Sub-IBAN / virtual IBAN
A sub-IBAN (or virtual IBAN, vIBAN) is an addressable IBAN that routes inbound payments into a designated sub-ledger of a master account, without requiring a separate bank account. Widely used by EMIs and fintechs to give each end-customer a unique IBAN at minimal cost, sub-IBANs are technically operator-owned, which can create AML attribution issues with some banks.

§07 · Corporate structuring & registry

Corporate structuring & registry.

The legal documents and registry concepts banks ask for during KYB onboarding.

16 terms

Articles of Association
The Articles of Association set out the internal rules of a company, including share rights, director powers, voting procedures, and meeting requirements. Banks request the Articles during KYB to verify ownership structure, signatory authority, and any provisions affecting control or transferability of shares.
Memorandum of Association
The Memorandum of Association is the founding document declaring a company's formation, name, registered office, and (in older common-law forms) its objects. In many modern jurisdictions the Memorandum has been merged into or simplified within the Articles, but offshore registries still issue both.
Certificate of Incorporation
The Certificate of Incorporation is the official document issued by a company registry confirming a company has been legally formed, with its registration number and date. It is the most basic KYB document a bank will request and is often the first item on any onboarding checklist.
Certificate of Good Standing
A Certificate of Good Standing is issued by a company registry confirming that an entity is currently registered, has filed all required returns, and is not in liquidation or strike-off proceedings. Banks typically require a recent (under 3 months old) Good Standing certificate at onboarding and at periodic refresh.
Certificate of Incumbency
A Certificate of Incumbency lists current directors, officers, and shareholders of a company, typically issued by the registered agent in offshore jurisdictions where this information is not publicly registered. Required by most banks for offshore entities to verify signatories and beneficial ownership chains.
Registered agent
A registered agent is a licensed person or firm appointed to receive official correspondence and legal service on behalf of a company in its jurisdiction of incorporation. Mandatory in most offshore jurisdictions (BVI, Cayman, Seychelles, Belize), registered agents also typically maintain the company's share register and issue incumbency certificates.
Registered office
The registered office is the official legal address of a company, where statutory correspondence is delivered and legal records are held. Banks check the registered office for substance and may reject applicants whose registered office is a known mass-incorporation address with no operational presence.
Apostille
An apostille is a standardised certificate authenticating the origin of a public document for use in another country, issued under the 1961 Hague Convention. Banks routinely require apostilled corporate documents (Certificate of Incorporation, Good Standing, board resolutions) for cross-border KYB.
Notarisation
Notarisation is the formal verification of a signature, copy, or document by a licensed notary public, attesting to its authenticity. Often a precursor to apostille, notarised copies of passports, utility bills, and corporate documents are standard requirements for high-risk KYB and PoA execution.
Annual return / annual filing
The annual return is the periodic filing a company must submit to its registry confirming directors, shareholders, and registered office, plus paying the annual fee. Failure to file leads to strike-off and loss of Good Standing, which in turn invalidates banking relationships.
Strike-off
Strike-off is the registry's removal of a company from the register, usually for non-payment of fees or non-filing, after which the company ceases to legally exist and its assets may vest in the state. Banks freeze accounts of struck-off companies, and recovering them requires formal restoration.
Restoration
Restoration is the legal process of reinstating a struck-off company onto the register, typically requiring payment of arrears, penalties, and a court or administrative application. Once restored, the company is treated as if never struck off, but the process can take weeks to months and disrupts banking and contracts.
Bearer shares
Bearer shares are share certificates whose ownership is determined by physical possession of the certificate, with no name registered. Effectively prohibited in most jurisdictions since the 2010s due to AML concerns, any company with historical bearer shares in its chain of ownership faces extreme banking difficulty.
Nominee director / nominee shareholder
A nominee director or shareholder holds the position formally on behalf of the actual beneficial owner, typically under a declaration of trust or nominee agreement. Legitimate in many jurisdictions, but banks always require disclosure of the underlying UBO and may decline structures where the nominee arrangement appears designed to obscure ownership.
Power of AttorneyPoA
A Power of Attorney is a legal instrument authorising one person to act on behalf of another, with scope ranging from general to single-purpose. Banks typically require PoAs to be notarised and apostilled, and may impose additional verification on the attorney before acting on PoA-based instructions.
Trust deed
A trust deed is the legal document creating a trust, identifying the settlor, trustee, beneficiaries, and the property held in trust along with the powers and obligations of the trustee. Banks reviewing trust accounts require sight of the full trust deed to identify the UBO chain and any provisions affecting how funds may be used.

§08 · Trade finance

Trade finance.

Bank instruments and documents that bridge trust between buyers and sellers in international trade.

7 terms

LCLetter of Credit
A bank instrument guaranteeing payment to a seller upon presentation of stipulated documents. LCs are widely used in international trade to bridge trust gaps between buyer and seller and are issued by banks against the buyer's creditworthiness or collateral.
SBLCStandby Letter of Credit
An SBLC is a payment guarantee issued by a bank that pays out only if the underlying obligation is not met by the principal. Functionally similar to a bank guarantee, SBLCs are widely accepted internationally and governed by ICC rules (UCP 600 or ISP98).
Escrow agent
An escrow agent is the neutral third party (often a bank, law firm, or specialist escrow company) that holds funds or documents in escrow and releases them upon fulfilment of contract conditions. Escrow agents are subject to KYC on both parties and must verify the satisfaction of release conditions before disbursing.
Documentary collection
Documentary collection is a trade-finance method where the seller's bank forwards shipping documents to the buyer's bank, releasing them only against payment (D/P) or acceptance of a draft (D/A). Cheaper than an LC but offers less protection, as the seller relies on the buyer's willingness to pay rather than a bank guarantee.
Bank guarantee
A bank guarantee is a written undertaking by a bank to pay a beneficiary if the bank's customer fails to fulfil a contractual obligation. Common in construction, government tendering, and international trade, bank guarantees are issued against collateral or credit lines and are typically governed by ICC URDG 758.
Performance bond
A performance bond is a specific type of bank or surety guarantee, ensuring that a contractor performs an underlying contract (typically construction or supply) to specification, with payout to the beneficiary if performance fails. Performance bond percentages typically range from 5–20% of contract value, depending on industry norms.
Bill of Lading
A Bill of Lading is the shipping document issued by a carrier acknowledging receipt of cargo and serving as a receipt, contract of carriage, and document of title. Negotiable bills of lading transfer title to the goods and are central to LC and documentary collection workflows.

§09 · Gaming revenue metrics

Gaming revenue metrics.

The headline numbers banks use to assess iGaming and betting operators.

5 terms

RTPReturn to Player
RTP is the percentage of total wagered money a casino game pays back to players over the long run, typically 92–98% for slots and over 99% for some table games. Regulators require RTP disclosure, and unusually low RTPs may trigger regulatory scrutiny and player complaints visible in chargeback patterns.
GGRGross Gaming Revenue
GGR is total amount wagered minus total winnings paid out to players, the operator's gross win before bonuses, taxes, and operating costs. GGR is the standard headline metric for the gambling industry and the base on which most gambling taxes (e.g., UK Remote Gaming Duty at 21%) are levied.
Related:NGR,RTP
NGRNet Gaming Revenue
NGR is GGR minus bonuses, free bets, jackpot contributions, and gaming taxes, representing the operator's revenue actually retained. Banks evaluating iGaming clients usually focus on NGR rather than GGR, since NGR is closer to economic reality and predicts the real cash flow available to service obligations.
Related:GGR
House edge
The house edge is the operator's long-run mathematical advantage on a game, expressed as a percentage of each wager and equal to 100% minus RTP. House edges range from under 1% on blackjack played optimally to 5–15% on most slots, and the figure determines theoretical operator profit.
Hold percentage
Hold percentage is the actual realised win as a percentage of money handled or wagered over a given period, distinct from theoretical house edge due to player behaviour and variance. In sports betting, "hold" typically means the bookmaker's margin built into the odds, usually 4–10% depending on market.
Related:GGR,House edge

§10 · Risk metrics

Risk metrics.

How banks classify a prospective client and decide whether and how to onboard them.

4 terms

Risk appetite
Risk appetite is the level and type of risk a bank or PSP is willing to accept, formalised in internal policy and translated into onboarding criteria. A bank's risk appetite for high-risk verticals can shift quickly under pressure from correspondents or regulators, leading to sudden offboarding even of compliant clients.
High-risk merchant
A high-risk merchant operates in a vertical with elevated chargeback, fraud, regulatory, or reputational risk, including iGaming, adult, forex/CFD, crypto, nutraceuticals, and travel. High-risk classification leads to higher MDR (typically 3.5–6%), mandatory reserves, restrictive contract terms, and limited acquirer choice.
Pre-approval
Pre-approval is an informal indication from a bank or PSP, given before formal application, that they would likely onboard a particular client based on a high-level review of structure, licences, and projected volumes. In high-risk banking, pre-approval saves weeks of work but is non-binding and can be withdrawn during full underwriting.
Related:Onboarding,KYB
OnboardingKYB onboarding
Onboarding is the full process of setting up a new banking or PSP relationship, from application through KYB, EDD, and final account activation. High-risk onboarding routinely takes 4–12 weeks and can require multiple rounds of documentation, calls with underwriters, and conditional approvals subject to volume caps.

§11 · Jurisdictional / offshore

Jurisdictional / offshore.

Concepts that determine how a structure is treated for tax, reporting, and bankability across borders.

5 terms

Offshore
Offshore refers to jurisdictions offering low or zero tax on foreign-source income and lighter regulatory disclosure, including the BVI, Cayman, Seychelles, Belize, and Nevis. Once the default for high-risk businesses, offshore structures are now significantly harder to bank due to FATCA, CRS, substance requirements, and bank derisking.
CRSCommon Reporting Standard
CRS is the OECD-developed standard for automatic exchange of financial account information between tax authorities, with over 110 participating jurisdictions. Banks in CRS-participating jurisdictions report customers' tax residency, account balances, and income annually, and CRS is now the global default for offshore tax transparency.
FATCA
FATCA (Foreign Account Tax Compliance Act) is US legislation requiring foreign financial institutions to report on US-person accounts to the IRS, enforced via 30% withholding on non-compliant institutions. FATCA preceded CRS and remains in force in parallel, making any US-touching account structure subject to ongoing reporting.
Related:CRS
Substance requirements
Substance (or economic substance) requirements oblige offshore companies to demonstrate genuine local activity, including local directors, employees, premises, and decision-making, to qualify for tax residency or licence retention. Introduced under EU and OECD pressure from 2018 onwards, substance rules have made pure shell-company structures unworkable for most regulated activities.
Beneficial owner registry
A beneficial owner registry is a government-maintained database of UBOs of legal entities, with varying degrees of public access depending on jurisdiction. EU Member States maintain UBO registries under AMLD5, the UK has the Persons of Significant Control register, and most major offshore jurisdictions now maintain non-public UBO databases.
Related:UBO,CRS

§12 · Technical / integration

Technical / integration.

The standards and APIs that define how modern banking systems talk to each other and to merchant tech stacks.

5 terms

PSD2Payment Services Directive 2
PSD2 is the EU directive (in force since 2018) regulating payment services, mandating SCA for online card payments and creating the legal basis for open banking via mandatory bank API access. PSD2 is the foundational rulebook for EU EMIs and PIs and underpins the entire European fintech ecosystem.
SCAStrong Customer Authentication
SCA is the PSD2 requirement for two-factor authentication on most electronic payments in the EU, combining two of: knowledge (password), possession (phone), and inherence (biometric). Implemented for cards via 3DS2 and for account access via dedicated authentication flows, SCA dramatically reduced card-not-present fraud after full enforcement in 2021.
Open Banking
Open Banking is the framework, mandated by PSD2 in the EU/UK and adopted voluntarily elsewhere, requiring banks to expose account data and payment initiation via standardised APIs to licensed third parties. Open Banking pay-by-bank is now a serious alternative to card payments, with no chargebacks and lower fees, particularly attractive for high-risk verticals.
ISO 20022
ISO 20022 is the international standard for financial messaging, replacing legacy SWIFT MT messages with rich, structured XML/JSON formats carrying significantly more data. SWIFT migration to ISO 20022 is in progress through 2025, and the richer payload directly improves AML screening, reconciliation, and compliance automation.
API banking
API banking is the provision of programmatic access to banking services (account opening, payments, balances, FX) via REST or similar APIs, allowing fintechs and merchants to embed banking into their own products. EMIs and challenger banks compete heavily on API quality, and rich API banking is a major reason high-risk businesses prefer EMIs over traditional banks.

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