# VAS Reliance Model

BCB uses a **risk-based reliance model** to onboard Corporate Clients into the **VAS** platform. This model ensures that reliance on a Corporate Client’s own AML/KYC program is only permitted once rigorous due diligence has been performed and contractual agreements are in place.

## Why a Risk-Based Model?

- **Mitigates BCB risk** by ensuring Corporate Clients maintain robust AML/KYC practices.
- **Enables efficiency & scalability** by leveraging clients’ existing compliance programs.
- **Supports ongoing compliance** through scheduled and trigger-based independent reviews.
- **Standards enforcement**: Client programs must meet RFI requirements. Where Bermuda regulation is less strict, **BCB’s standards prevail**.


## The Onboarding Journey

The reliance model follows a structured onboarding flow:

1. **Corporate Client VAS Demand Queue**
  - Incoming client interest is added to a demand queue.
2. **VAS Expression of Interest**
  - Client formally expresses interest in the VAS program.
3. **Client Risk Questionnaire** *(risk rating)*
  - Client completes a risk self-assessment.
  - Used to calculate an initial AML/KYC risk rating.
4. **Independent AML/KYC Assessment** *(as needed)*
  - Performed where risk level or information gaps require independent validation.
  - Scope may include audit methodology, sampling, and testing plans.
5. **VAS Client Agreement**
  - Formal contractual agreement between BCB and the Corporate Client.
  - Establishes reliance terms for AML/KYC responsibilities.
6. **Ongoing Independent AML/KYC Assessments**
  - Conducted at regular intervals, with frequency based on client risk profile.
  - May also be triggered outside scheduled reviews.
  - Ensures client AML/KYC practices remain compliant and enforceable.