Pass partner diligence with real evidence, not screenshots
Sponsor banks run Section 8 diligence reviews that demand evidence your BSA/AML and OFAC controls ran. Your compliance team gets examiner-ready answers backed by enforcement records, structured exports, and cryptographic proof.
What sponsor banks and partners usually ask
Every question maps to controls and evidence Kontext captures automatically.
“Who or what initiated this payment?”
Initiation source tracking for human, workflow, API, or AI-agent actions, including the service or agent identity and instruction reference.
“Who approved this payment?”
Full approval chain with timestamps, authority level, and policy reference for every payment decision.
“What checks ran before funds moved?”
OFAC/SDN screening results, EDD threshold checks, and counterparty verification — all with proof they ran before execution.
“Was the payment blocked, approved, or escalated?”
Explicit enforcement mode and disposition tracking so reviewers can see whether a payment stayed advisory, was blocked, or was routed into human review.
“Which policy version was in force?”
Exact policy rules evaluated at decision time — threshold values, approval requirements, screening configurations.
“Can this record be independently verified?”
Digest proof returned with events and portable export files that can be verified by auditors, counterparties, or regulators.
“How do you handle GDPR, erasure, and redaction?”
PII separation, subject access exports, erasure workflow logging, and redacted export modes for non-compliance audiences.
“Can you export the evidence?”
Structured case packets in JSON, CSV, examiner-ready, partner diligence, incident review, or redacted formats.
A sample diligence packet for a single payment
Every payment decision produces a structured evidence record with initiation source, enforcement state, policy checks, screening results, export controls, and verification proof.
Amount
$48,200 USDC
Type
Vendor payout
Corridor
US → EU (Base)
Timestamp
2026-03-21 09:14 UTC
Enforcement
Blocking mode
Initiator type
AI agent
Agent ID
treasury-rebalancer-v2
Instruction ref
payout batch #A-449
SDN v2026.03.21 · Checked at 09:14:02 UTC · 38ms
Disposition
Approved after dual review
Fallback
Blocked if approval missing
Policy version
payout-policy@2026.03
Treasury Ops
09:12 UTC
Compliance
09:13 UTC
Execution
09:14 UTC
Verification proof
digest #2,341 returned with event
Content hash
sha256:a4f2c8...7e1d3b
Packet types
Examiner, diligence, incident
Redaction mode
First6...last4 masking
SAR / erasure log
Preserved in audit trail
Where most payment startups fall short
- No tamper-evident proof that compliance checks ran before payment execution
- Audit trails reconstructed after the fact from application logs
- Screening evidence stored separately from payment records
- No structured export format — diligence responses built from screenshots
- Policy versions not captured at decision time, making retroactive review unreliable
- No clear answer for right-to-erasure or redacted diligence exports
FFIEC BSA/AML first-request letter items
The FFIEC BSA/AML Examination Manual (Appendix H) defines 130+ document categories in a standard first-request letter. Here is how Kontext maps to the most common third-party payment processor items.
| FFIEC Request Item | What Examiners Want | Without Kontext | With Kontext |
|---|---|---|---|
| Processor policies & procedures | Written controls documentation | Confluence, Google Docs, scattered | Policy version captured per decision |
| Transaction details & volume | Activity records with amounts, parties, dates | Core banking + blockchain explorer + processor dashboard | Unified activity view across all rails |
| SARs filed on processor relationships | Filing history with supporting docs | Case management + FinCEN BSA E-Filing | SAR workflow with linked evidence packets |
| NACHA return correspondence | High return rate documentation | Email + NACHA portal | Alert evidence linked to payment records |
| Screening results | OFAC/SDN check evidence | Screening vendor dashboard | Timestamped, cryptographically linked to each payment |
When AI agents are part of the payment flow
If software agents can initiate, recommend, or influence payment actions, reviewers often need additional clarity on initiation source, control boundaries, approval requirements, and exception handling. Kontext packages this context into the same evidence workflow used for broader diligence and audit preparation.
Evidence reviewers can verify, govern, and export
Independent verification
- Digest proof returned with verification events
- Export files that third parties can validate independently
- Portable evidence across wallet, processor, and banking stacks
GDPR and data governance
- PII separation from the cryptographic audit record
- Subject access exports and redacted diligence packets
- Erasure workflow logging without breaking audit integrity
Diligence prep before and after Kontext
- Weeks of manual evidence collection
- Screenshots and spreadsheets for reviewers
- No proof screening happened before execution
- Inconsistent formats across payment rails
- Re-do prep every time a partner asks
- Structured evidence packets generated automatically
- Examiner-ready exports replace ad hoc collection
- Cryptographic proof of screening sequence
- Unified evidence format across all payment rails
- Diligence responses backed by verifiable evidence
Built for the questions reviewers actually ask
The site should answer reviewer questions before they turn into diligence fire drills: initiation source, enforcement state, policy version, verifiability, and data governance.
Sponsor bank reviewer
Internal auditor
Enterprise due diligence team
Be ready for your next partner review
See how your payment stack scores against common diligence requirements.