Jules

commission work

can you stop staring, she only has 15 minutes

#signalis #fanart

bauhaus fleeper for the warmup, i probably shouldve used shape tools instead of trying to hand draw curves but such is life

Yes twitch fucked up in not requiring you to scan your ID literally in 2020 when it became law and January 2026 when the grace period ended. They are playing catch up and it’s moronic it took them this long.

If Twitch paid you under contract to stream there (like Kick does with some streamers), there would be no KYC obligation.

Since they are acting literally the equivalent of a bank in this transaction, they need to KYC you. I do this for a living. Please read what I am saying.

It is much simpler and usually much cheaper to pay a vendor to provide a service that ASSISTS ME in verifying YOU.

YOU might be the vendor, but TWITCH IS NOT PAYING YOU FROM THEIR FUNDS. They are acting as a pass though. They are collecting money from others, and pooling it, then distributing it.

God I’m sorry, you are impossible. I literally do this for a living. It does not conflict. Read.

Under the law, nondelegable means you can’t just assume someone else has done it. Persona is a vendor that allows people like me to collect information on people like you for a financial relationship.

The likely answer for why its now is that Twitch is playing catch-up on compliance. Both FinCEN and FINTRAC both got serious recently about AML (probably connected to Ukraine/Cartel stuff?) and are becoming far more strict.

Twitch operate a platform that pools revenue from millions of purchasers, calculates individual payouts and distributes funds to thousands of recipients. They are functionally operating as a payment service provider, which makes them an MSB under the PCMLTFA (and under FinCEN definitions in the US).

Twitch IS NOT a normal business client paying an invoice. You are not understanding this. Twitch sits in the middle of a payment flow, and that's what triggers the regulatory obligation. Twitch is transmitting money on behalf of its ad/sub/bits revenue streams to individual payees.

Not everyone is a reporting entity. The PCMLTFA doesn't impose KYC on all businesses universally, it applies to specific categories: banks, MSBs, securities dealers, insurers, accountants, real estate, casinos, etc.

KYC obligations are nondelegable. Each reporting entity has its own independent obligation, your bank's verification of you satisfies your bank's obligations. Twitch cannot call up TD and say "hey, did you verify this person?" and check the box.

Publicly traded companies have beneficial ownership disclosed through securities regulators. When Microsoft buys cloud services from Amazon, that's a B2B commercial transaction handled through corporate banking relationships where KYC was already performed by their respective banks.

A photo ID is one of the ways we are legally permitted to collect the legal name and DOB, and then screen against OFAC/consolidated sanctions lists. "Just trust me" or "refer to my company" is not enough.

Twitch doesn't ID people for donations because KYC for those purchasers is handled upstream by the card networks and issuing banks. Visa/Mastercard's issuing bank already verified that cardholder's identity when they opened the account.

Under the PCMLTFA, Twitch is acting as an MSB (or at minimum a payment service provider), and the person they're sending money to is their client for AML purposes. It doesn't matter who's providing a "service" to whom commercially, what matters is who's moving money to whom.

Not to be rude, but I am not making an argument. I am explaining the law.

This confuses the commercial relationship with the financial/regulatory one. When Twitch pays out a streamer, Twitch is conducting a financial transaction and the streamer is the recipient of funds.

CRA/IC lookups don’t satisfy FINTRAC’s prescribed identification methods! The regulations specify acceptable methods (government-issued photo ID, credit file, dual-process method, etc.). Knowing someone is a corporate director doesn’t fulfill the individual identification requirements.

KYC obligations are one-directional by statute. The reporting entity (Twitch, as an MSB processing payouts) has a legal duty to identify its clients. There’s no corresponding legal obligation flowing the other way.

FINTRAC/FinCEN doesn’t send you a polite request to verify someone, they conduct examinations and expect your KYC records to already be in compliance. The entire point of AML/KYC obligations is that you verify identity before or at the time of the business relationship.

Usually clients don’t even do it in one sitting it’s so daunting lol

This is not enough! This would not satisfy a FinCEN/FINTRAC warning letter!

Source: i work in a place that requires sanctioned individual checking and the amount of info you need to ‘verify’ someone is who they say they are and the money comes from where they say feels perverse to most!

Die Toteninsel

I LOVE #WOMEN

klbr but shes a cat girl or something #signalis

козак

Swan lake

Go jerk off