Decentralized Vaults
Fairway Vaults are off-chain, decentralized storage environments for KYC/AML data. They ensure compliance with FATF standards and GDPR/eIDAS while enabling privacy-preserving, proofs of compliance.
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Fairway Vaults are off-chain, decentralized storage environments for KYC/AML data. They ensure compliance with FATF standards and GDPR/eIDAS while enabling privacy-preserving, proofs of compliance.
Customer Due Diligence (CDD) → Collect and verify customer identity documents.
Record Keeping → Maintain records for 5–10 years, available for regulators on request.
Sanctions Screening → Check against updated lists (UN, OFAC, EU, local).
Ongoing Monitoring → Reassess at regular intervals or when risk events occur.
Document Verification (passport, national ID, proof of address).
Risk-based Approach → Different levels (KYC1, KYC2, Enhanced Due Diligence).
Accreditation/Eligibility → Investor class checks for RWA access.
Data Minimization → only necessary data collected.
Right to Erasure / Portability → users can revoke and migrate.
Encryption & Scoped Access → Vault encrypts data at rest and in transit.
Separation of Concerns → Vault handles PII; blockchains only handle proofs & commitments.
Collection → user submits KYC docs to Vault (off-chain, encrypted).
Verification → Cloud Agent validates docs (document checks, sanctions screening, AML rules).
Proof Generation → Witness calls Cloud Agent and Compact circuit produces ZK-proof bound to a wallet address.
Recording → Proof stored as a UTXO on Midnight (immutable audit trail).
Reference → Merkle roots (Cardano) or EAS attestations (EVM) include midnight_ref and Fairway signature.
Usage → dApps only check eligibility flags; no direct access to PII.
FATF R.10 / R.11 (Recordkeeping) → Vault maintains secure audit trail; regulators can request full trace via midnight_ref.
AML Directives (AMLD5/6, EU) → sanctions screening + enhanced due diligence supported by Vault Agent workflows.
GDPR Articles 5 & 25 (Minimization, Privacy by Design) → only commitments/flags on-chain, never PII.
eIDAS → cryptographic signatures and proofs meet EU electronic trust service requirements.
Auditability → any midnight_ref can be checked against Vault + Issuer records under regulator supervision.
✅ Are → encrypted, decentralized KYC data stores aligned with FATF/AML/GDPR.
❌ Are Not → on-chain databases (no PII ever published).
❌ Are Not → public APIs for dApps (only the Witness Agent reads them).
❌ Are Not → proof stores (ZK-proofs live on Midnight).
Privacy-first → regulators can audit, but protocols see only “YES/NO”.
Regulatory alignment → satisfies FATF, AMLD, KYC, GDPR/eIDAS simultaneously.
Future-proof → Vault workflows adapt to new directives (e.g., FATF Travel Rule, MiCA).
Trust-minimized → Fairway signature + Midnight proofs decouple compliance checks from raw data custody.
See Witnesses → how Cloud Agents read Vaults and generate proofs.
Learn Zero-Knowledge Proofs (Midnight).
Explore Compliance Guides for regulator mapping.
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{
"user_id": "uuid-v4",
"wallets": ["addr1...", "0xabc..."],
"kyc_level": 2,
"jurisdiction": "EU",
"accredited": true,
"sanctions_status": "clear",
"docs": {
"passport_hash": "sha256:0x123...",
"proof_of_address_hash": "sha256:0x456..."
},
"created_at": "2025-09-22T10:15:00Z",
"updated_at": "2025-09-22T11:00:00Z"
}