Compliance & Onboarding | Tesseract Documentation

For the complete documentation index, see llms.txt. This page is also available as Markdown.

Availability. Tesseract Investment Oy does not provide services to persons in the United States, the United Kingdom, the United Arab Emirates, Japan, South Korea, Singapore or Australia. Service availability in other jurisdictions is subject to Tesseract's assessment of applicable regulatory and sanctions requirements.

Overview

All clients onboarding to Tesseract Dedicated Client Vaults must complete Know Your Customer (KYC) or Know Your Business (KYB) verification before vault deployment. These are legal obligations under the EU Anti-Money Laundering Directives (AMLD), FATF Recommendations, and Finland's AML Act.

Tesseract uses Sumsub as its secure verification provider for both KYB and KYC flows.

KYB Requirements (Corporate Clients)

The KYB flow has three parts: a company questionnaire, company documents, and identity checks for key individuals.

1. Company Questionnaire

The questionnaire covers basic company and tax information:

• Company details: legal name, legal form, registration number, registration authority, tax residency, registered address, and contact details (email and phone)
• Legal Entity Identifier (LEI): required for all corporate clients
• PEP declaration: whether any beneficial owners or directors are politically exposed persons or closely related to them
• Origin of assets: main sources of the company's funds (e.g. operating income, dividends, loans, sale of property or company, investment income)
• Business profile: description of activities, main industries, key markets or countries of operation, and basic financial information such as turnover and balance sheet size
• Expected activity: approximate size and frequency of transactions and which services are intended to be used

2. Company Documents

Clear electronic copies of core corporate documents are required:

• Certificate of incorporation or certificate of registration
• Memorandum and articles of association or equivalent governing documents
• Shareholder register showing current ownership
• Recent company registry extract from an official state or trade registry
• Proof of registered address (e.g. recent utility bill, bank statement, or official letter)

Freshness requirements: Some documents must be recent (max 3 months old) and clearly dated and signed by the issuer or responsible party. These include: shareholder register, official registry extract, and any incorporation document provided as a registry extract.

3. KYC Checks for Key Individuals

As part of KYB, the following individuals must be verified:

• At least one legal representative authorized to sign on behalf of the company (includes liveness check)
• Ultimate Beneficial Owners (UBOs) — individuals who directly or indirectly own or control more than 25% of shares/voting rights
• Directors and senior management where required by internal procedures

Each person completes an individual KYC flow: government-issued ID and a selfie/video liveness check (for representatives).

KYC Requirements (Individual Clients)

For individual clients, the KYC process focuses on confirming identity, personal information, and AML-relevant background.

Information Required

• Personal details: full name, date of birth, nationality/nationalities, residential address, contact details, tax residency and TIN
• PEP declaration: whether you are a politically exposed person, family member, or close associate
• Origin of assets: source of funds (e.g. salary, savings, proceeds from sales, inheritance, investment gains including digital assets)
• Employment and financial profile: employment status, occupation, industry sector, income/wealth ranges
• Intended use: planned services, approximate transaction size and frequency

Documents Required

• Valid government-issued identity document (passport or national ID card)
• Selfie or live video for liveness and face match
• Proof of address — utility bill, bank statement, or official letter, max 3 months old

In certain circumstances, additional source of funds and wealth documentation may be requested.

Onboarding Process

The client journey is fully online and runs inside the Tesseract Compliance app at compliance.tesseract.fi:

1. Sign in and pick KYC (individual) or KYB (company).
2. Complete the Sumsub flow — questionnaire, document uploads, and ID / liveness checks all happen inside the app. For KYB, key persons receive individual links for their own KYC steps.
3. Suitability assessment. Tesseract Investment Oy conducts a suitability assessment in accordance with MiCAR Article 81 and ESMA's 2025 Guidelines on suitability, before any vault is deployed.
4. Automated checks — Sumsub validates documents and screens against sanctions and PEP lists. Follow-up questions, if any, appear inline.
5. Connect a wallet and sign the ownership challenge. One or more wallets can be added; each is screened for AML risk.
6. Whitelisting. Once KYC/KYB, the suitability assessment and wallet screening pass, Tesseract writes each wallet to the on-chain Whitelisting contract with a KYC-expiration timestamp. The wallets can now deploy and operate vaults.

Two onboarding paths

The flow above describes the standard direct path — the client completes KYC/KYB themselves via compliance.tesseract.fi and Sumsub. This covers both retail individuals and institutions onboarding as their own Tesseract client.

Partner-led onboarding (custodian model) is an alternative path for partners offering DCVs to their own end users. The partner and Tesseract agree on a compliance model up front — full KYC by Tesseract, reliance on the partner's existing KYC, or a hybrid — and the partner provisions users programmatically via Tesseract's Compliance API.

Both paths end the same way: the wallet is written to the on-chain Whitelisting contract with a KYC-expiration timestamp.