Compliance operating model

Understand the public compliance responsibility split between your platform, Roots, and the partner bank.

Understand how Roots and its partner bank divide compliance responsibilities across the platform.

See API availability before using a compliance-dependent workflow in production.

Operating model

Roots operates first-line compliance controls for the program. Roots collects information, validates completeness, runs configured checks, manages cases and requests for information, and applies permitted platform controls.

The partner bank retains final authority for decisions reserved to the bank. Those decisions can include relationship approval, enhanced due diligence approval, sanctions outcomes, release from bank-controlled holds, material restrictions, and regulatory reporting.

sequenceDiagram
  participant Client as Client platform
  participant Roots as Roots
  participant Bank as Partner bank

  Client->>Roots: Submit onboarding or payment data
  Roots->>Roots: Apply first-line controls
  alt Clear and bank approval required
    Roots->>Bank: Submit required approval package
    Bank-->>Roots: Approve, request information, restrict, or reject
  else Exception or escalation
    Roots->>Bank: Escalate case and evidence
    Bank-->>Roots: Record final decision where required
  end
  Roots-->>Client: Return status and applicable controls

Roots responsibilities

Roots provides the platform controls that support the program, including:

  • Collecting customer, associated-person, counterparty, and payment information.
  • Validating required fields, documents, and eligibility rules.
  • Orchestrating identity verification, screening, and monitoring checks.
  • Normalizing results and maintaining the Roots compliance outcome record.
  • Creating RFIs, cases, holds, and permitted temporary restrictions.
  • Preserving audit history and evidence references.
  • Routing matters that require a partner-bank decision.

Partner-bank responsibilities

The partner bank performs independent validation and retains final decision authority where the program requires it.

Decision areaRootsPartner bank
Standard data validation and screening orchestrationPerformsOversees the approved control framework
Account or product activation requiring a bank gatePrepares and submits the recordApproves, restricts, requests information, or rejects
Enhanced due diligenceCollects and reviews the packageApproves when required
Potential sanctions matterHolds and escalates the caseMakes the final sanctions decision
Release from a bank-controlled holdKeeps the control in placeApproves release when required
Regulatory reportingPreserves and escalates evidenceDetermines and performs required filings

Fail closed

Roots applies a fail-closed approach when a mandatory sanctions check cannot be completed. A payment must not proceed without the required screening.

An expired deadline, unresolved RFI, or elapsed hold period does not authorize automatic release. Keep the affected activity blocked until Roots records the required outcome.

Bank gate

A clean Roots first-line result does not by itself activate an account or product when a bank gate applies.

Before the required approval is recorded, Roots must not enable the affected account instructions, incoming funding, funds access, outgoing payments, or product capability. A new product, account type, payment rail, or higher-risk corridor can require a new gate.

Next steps


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