# KYC SPIDER Corporate KYC/KYB, Screening and Compliance Intelligence (Regulatory and Technical Memorandum) ## I. Systemic Role within SwissChain Control Architecture Within SwissChain's overall control and onboarding architecture, **KYC Spider (kyc.ch)** functions as the primary **corporate KYC/KYB and compliance-intelligence layer** for legal entities and their beneficial owners. While front-end identity capture and onboarding flows can involve other tools, KYC Spider is the core system through which SwissChain's operating subsidiaries perform structured due diligence on companies, verify UBO structures, and continuously screen counterparties against sanctions lists, PEP registers and adverse media databases. KYC Spider is not a customer-facing brand within the Moonkey ecosystem; instead, it operates as a specialised Swiss RegTech platform that SwissChain accesses via the **KYC Toolbox** web interface and APIs. Practically, this positions KYC Spider between SwissChain's onboarding and CRM systems and its banking, custody and trading stack: before a corporate client can be onboarded to fiat rails (Fiat Republic), custody (DFNS) or execution (Scrypt or Moonkey), the legal entity, its directors and UBOs are subjected to KYC Spider-driven screening and risk classification. This design ensures that **corporate flows entering the SwissChain ecosystem are pre-filtered** through a dedicated KYB engine rather than being assessed manually or via generic retail KYC tools, which are often inadequate for complex corporate structures. For banking partners, regulators and institutional investors, KYC Spider is thus a critical proof point that SwissChain's corporate onboarding and counterparty risk management rely on a **Swiss-based, institution-grade compliance platform** rather than ad hoc internet searches or unverified data sources. The KYC Toolbox centralises customer data, screening results, risk assessments and documentation into a single environment, so that SwissChain's compliance team can demonstrate consistent application of policies, reproducible decisions and full audit trails for every corporate relationship. ## II. Legal Nature, Regulatory Perimeter and Market Positioning KYC Spider is operated by **KYC Spider AG**, a Swiss RegTech company headquartered in Switzerland and part of the Eurospider group, which has long-standing expertise in search technology, data analytics and compliance solutions for financial institutions. As a software and data provider rather than a financial intermediary, KYC Spider is not itself an AML-obliged entity in the same sense as banks or securities firms; instead, it delivers tools, data and infrastructure that enable regulated institutions to meet their own AML, CFT and sanctions-compliance obligations under Swiss and EU law. KYC Spider positions itself as a **digital compliance platform ("KYC 4.0")** covering the full life cycle of KYC and KYB - from initial onboarding of clients, through ongoing monitoring and periodic review, to offboarding and archival. Its core product, the **KYC Toolbox**, is marketed to banks, asset managers, fiduciaries, fintechs and other regulated entities as a modular environment where they can configure risk-based workflows, connect to curated databases (sanctions, PEPs, watchlists, company registers, adverse media) and generate structured KYC files suitable for internal audit and regulatory inspection. Public materials emphasise that the platform is built specifically for regulated environments, with an emphasis on explainable risk scoring, traceability of decisions and integration with existing compliance processes rather than black-box automation. In market terms, KYC Spider occupies a **specialist RegTech niche** in the Swiss and European financial-services ecosystem. It is referenced in industry media and RegTech overviews as a leading provider of digital KYC and compliance automation in Switzerland, recognised for its ability to consolidate multiple data sources and regulatory requirements into a cohesive toolbox for compliance teams. For SwissChain, this positioning matters: using a Swiss-based KYC and KYB specialist that already serves banks and financial intermediaries provides external comfort that the underlying tools and datasets meet institutional expectations. ## III. Certification, Data Protection and Assurance Framework KYC Spider's assurance framework is anchored primarily in **Swiss and EU data-protection regimes** and in the compliance expectations of its regulated client base. As a Swiss company handling sensitive personal and corporate information, KYC Spider operates under the Swiss Federal Act on Data Protection (FADP) and, where EU data subjects are involved, under the EU General Data Protection Regulation (GDPR). Public information indicates that KYC Spider hosts its services and data predominantly in Switzerland, a point repeatedly highlighted as part of its value proposition to Swiss banks and financial intermediaries who require local data residency and strong privacy guarantees. KYC Spider's technology stack and processes are not publicly associated with specific ISO or SOC certification numbers, but its **compliance-first positioning and long-standing relationships with regulated institutions** imply internal adherence to industry-standard security and operational controls. External articles and vendor profiles describe KYC Spider's tools as being used by banks and other AML-obliged entities for sanctions and PEP screening, adverse-media checks and high-risk-jurisdiction assessments, which indicates that its datasets and screening logic are regularly scrutinised by internal audit and supervisory bodies at client institutions. For SwissChain, assurance is further supported by its own **vendor-risk framework**: KYC Spider is treated as a critical RegTech provider, subject to due-diligence reviews, contractual data-processing agreements, and periodic reassessment of security, data-protection and service quality. Under this framework, SwissChain's compliance and risk functions verify that KYC Spider's data sources are reputable, update cycles are adequate, false-positive management is configurable, and data-retention policies are compatible with SwissChain's own regulatory obligations. ## IV. Core Technical Architecture and Control Surface At a technical level, KYC Spider's **KYC Toolbox** provides a central environment where SwissChain's compliance staff can orchestrate corporate KYC and KYB processes. The platform combines: - A **data layer** aggregating structured information from sanctions and embargo lists, politically exposed persons (PEPs) databases, law-enforcement and regulatory watchlists, commercial registers, beneficial-ownership registries (where accessible) and curated news and adverse-media feeds. - A **workflow engine** that allows SwissChain to define risk-based processes, for example differentiating between low-risk corporates and high-risk complex structures by adjusting the depth of information required, the screening intensity and the levels of approval. - A **case-management and documentation interface** where each corporate client is represented by a file containing identification documents, ownership charts, screening results, risk scores, internal notes and decisions, which together form the official KYC dossier for audit and supervisory purposes. From SwissChain's perspective, KYC Spider's control surface includes **screening, monitoring and review**: - At onboarding, the legal entity, its directors and UBOs are checked against sanctions and PEP lists, and adverse-media searches are run to identify potential reputational or financial-crime links. Matches are categorised by severity and confidence, enabling targeted review rather than generic pass or fail flags. - During the relationship, KYC Spider provides **ongoing screening**; when sanctions lists or PEP registers are updated, existing clients are re-screened, and any new matches generate alerts. This supports SwissChain's obligation to periodically reassess client risk and to respond quickly to new sanctions or adverse information. - For periodic KYC refresh or event-driven review (for example a change of ownership), the existing KYC file can be updated and re-validated within the Toolbox, maintaining a continuous audit trail of changes and compliance decisions. The platform can be used via browser-based GUI and, where needed, API integration with SwissChain's internal systems. This hybrid model allows gradual integration: initial onboarding and risk assessment can be performed manually by compliance analysts using KYC Spider's interface, while later phases may automate parts of the data flow (for example pushing client identifiers and basic data from CRM to KYC Spider, then retrieving risk results). ## V. Risk Mitigation Mechanics and Residual Risk For SwissChain and its operating subsidiaries, KYC Spider mitigates several **core compliance risks** associated with corporate onboarding and counterparty relationships. First, it **reduces the risk of onboarding sanctioned or high-risk entities** by systematically screening legal entities, directors and UBOs against up-to-date sanctions lists, PEP registers and negative-news databases. This structured process is more robust than ad hoc manual searches and significantly lowers the probability of missing publicly known risk indicators. Second, KYC Spider's adverse-media and reputational-risk screening reduces the chance of SwissChain entering into relationships with entities linked to fraud, corruption, money laundering or other controversies that may not yet have resulted in formal sanctions but are nonetheless material from an AML/CFT and reputational standpoint. Third, the Toolbox's case-management and audit-trail features mitigate **governance and internal-control risk**: every decision (for example to accept or reject a client, to apply enhanced due diligence, or to classify a counterparty as high risk) is documented and linked to underlying screening results and data. This provides defensibility in front of auditors and regulators: SwissChain can demonstrate that decisions were made on the basis of structured information and documented reasoning, not arbitrary judgment. Residual risks remain and are managed explicitly. KYC Spider, as a data and tooling provider, does **not replace SwissChain's own responsibility** for AML, CFT and sanctions compliance; false negatives can still occur if information is missing from databases, and false positives must be resolved by human review. Moreover, while KYC Spider aggregates multiple data sources, it is ultimately dependent on the quality and timeliness of those sources; SwissChain's compliance governance must therefore include periodic validation of data quality, calibration of risk thresholds and continuous training of staff in interpreting screening results. Finally, concentration risk at the vendor level exists: KYC Spider is a critical RegTech provider, and any prolonged outage or degradation in service could affect SwissChain's ability to onboard or review corporate clients; this is addressed by business-continuity planning, contractual SLAs and the possibility of fallback workflows (for example temporary manual checks using alternative sources in case of disruption). ## VI. Integration with SwissChain Stack and Control Flows In SwissChain's target operating model, KYC Spider is integrated at the **corporate onboarding and monitoring** layers, primarily for legal entities interacting with SwissChain Holding SA and Moonkey-branded operating subsidiaries. The typical control flow is: 1. A corporate prospect initiates onboarding (for example to invest in participation certificates, to become a B2B partner, or to use Moonkey services). Basic corporate data and documentation are collected via SwissChain's front-end processes. 2. SwissChain's compliance team enters or synchronises the relevant data into KYC Spider's KYC Toolbox, which then performs sanctions, PEP and adverse-media screening on the entity, directors and UBOs. 3. KYC Spider returns risk indicators and potential matches; compliance analysts review the results, request additional information where needed, classify the client's risk level and document their decision in the KYC file. 4. Only once the KYC and KYB dossier is approved in KYC Spider is the corporate client activated within SwissChain's operational systems and allowed to interact with fiat rails (Fiat Republic), custody (DFNS), execution (Scrypt) or Moonkey products. 5. Throughout the relationship, KYC Spider continues to screen the client against updated lists and media; any new material information triggers alerts and, where necessary, a review, temporary freeze or termination of the relationship. For banks, listing venues and institutional investors examining SwissChain's compliance posture, this integration demonstrates that **corporate onboarding is anchored in a specialised Swiss RegTech platform used by other regulated institutions**, that risk decisions are documented and reproducible, and that the KYB layer is clearly separated from commercial and trading functions. KYC Spider thus forms a key part of SwissChain's narrative that its ecosystem is not just technologically sophisticated, but also aligned with the compliance expectations of the traditional financial system.