Security, data and compliance in Digital Member Onboarding (KYC/CIP)

How Digital Member Onboarding (KYC/CIP) protects data and supports your compliance obligations.

Security controls

Single sign-on

Staff sign in through your identity provider, so your password and multi-factor policies apply.

Role-based access

What each person can see and do follows their role; changing decision rules is separate from working exceptions.

Biometric data handling

Selfies and liveness data are used only for verification, with notice and consent captured, and retained or deleted under the schedule you set to meet applicable biometric privacy laws.

Encryption and keys

Client data, including document images, is encrypted, with keys Moraph staff cannot use without explicit, time-bound authorization.

Complete audit trail

Every application, check result, decision, rule change and export is logged with the person or rule and time, and cannot be edited.

Data residency

Data stays in the hosting region you choose: the United States, the United Kingdom or Australia.

Requirements it supports

• USA PATRIOT Act Section 326 and the Customer Identification Program rule (31 CFR 1020.220)
• FinCEN Customer Due Diligence Rule (31 CFR 1010.230)
• OFAC sanctions regulations (31 CFR Chapter V)
• Electronic Signatures in Global and National Commerce Act (E-SIGN, 15 U.S.C. 7001 et seq.)
• Gramm-Leach-Bliley Act and Regulation P (12 CFR Part 1016)
• State biometric privacy laws, such as the Illinois Biometric Information Privacy Act (740 ILCS 14)

The product supports these requirements; meeting them remains your organization's responsibility.

Where it runs

• Moraph cloud: Hosted and operated by Moraph in the United States region. United Kingdom and Australia regions are available for institutions outside the US.
• Dedicated environment: A single-tenant environment for institutions whose policies require isolation, scoped in the proposal.
• Branch-assisted use: The same application can be used by staff in a branch or on a tablet with the applicant present, with the channel recorded.

Limitations

• Verification results depend on the identity verification services and data sources configured. No check is conclusive on its own, and your institution decides how results are used under its CIP.
• Some applicants cannot complete document capture or a liveness check, for example because of their device, document type or a disability. Your procedures should provide another way to open an account, and the product supports routing them to staff.
• It does not replace your BSA officer's judgment. Decision rules are set and approved by your institution, and the product applies them as configured.
• It does not hold, move or fund accounts. Funding uses your existing methods, and accounts are opened in your core system.
• It is not a transaction monitoring system; ongoing monitoring happens in your AML system, such as Moraph's AML & SAR Automation Hub.
• It is designed for US CIP and due-diligence requirements. Onboarding in other countries may need different documents, checks and disclosures.
• How long an application takes depends on the applicant and on any exception review; the product does not promise an account-opening time.
• Lending applications and credit decisions are not included.