Who Verifies What

Your compliance model decides who collects identity data and who verifies it. Rain screens every party either way.

The first thing to settle in a compliance integration is who does what. Rain offers two compliance models. Under Standard Compliance, Rain collects and verifies customer identity directly. Under Hybrid Compliance, you verify customers in your own compliance program first, and Rain still screens every party.

That single difference changes what you send, what you do not have to send, and how strictly country rules apply.

Your compliance model is separate from your management model. Rain-Managed and Partner-Managed describe how collateral and funds are handled, not who verifies your customers.

Responsibilities by compliance model

The following table compares the two models across both verification pipelines:

	Standard Compliance	Hybrid Compliance
Collect identity data	Rain	You
Consumer applicant’s identity document and selfie	Required	Not required
Verify identity	Rain	You, in your own compliance program
AML, PEP, and sanctions screening	Rain	Rain
On-chain screening, when a wallet address is present	Rain	Rain
UBO checks	Reviewed by Rain’s compliance team	Run automatically alongside representatives
Country and jurisdiction rules	All rules apply	Only hard-blocked countries are rejected outright
Payments account owner check (CIP)	Rain runs the check	You verify the account owner; Rain still screens the party

Screening is the row that never moves. Every applicant is screened in both models, so even if you have already cleared a customer under Hybrid Compliance, Rain can still place that customer in manual review or reject them.

What changes for a person

Under Standard Compliance you submit the full consumer profile, an identity document, and a selfie with a liveness check. Verification begins once all three are present.

Under Hybrid Compliance you submit only the identifying fields, because you have already verified the person. No identity document or selfie upload is needed. Rain runs AML, PEP, and sanctions screening on the applicant.

What changes for a business

Under Standard Compliance you submit the company’s full profile along with its supporting documents.

Under Hybrid Compliance you manage your own company due diligence. Rain requires the company’s identifying fields and runs AML, PEP, and sanctions screening on the company, on every representative, and on every UBO.

Both models require the people behind the business. Representatives and Ultimate Beneficial Owners are part of a corporate application either way, and UBOs provide an identity document in both models. What differs is whether Rain’s compliance team reviews the UBO checks or they run automatically. See Ultimate Beneficial Owner (UBO).

What does not change

Three things are the same in both models:

• Screening: AML, PEP, and sanctions screening runs on every party, plus on-chain screening through Chainalysis whenever a wallet address is provided.
• Two separate gates: Cards approval and payments approval are independent. Clearing one does not clear the other.
• Hard-blocked countries: these are rejected in both models. Only the unsupported-state and soft-blocked rules relax under Hybrid Compliance.

What’s next

Verification requirements

The field-by-field tables for each model, the country rules, and how screening works.

Choose your model

Pick your program type and management model, if you have not already.

Payments compliance

The separate gate that gates money movement rather than card issuance.