RISK HOMEWORK ·Due Diligence Analyst, APAC, Alpaca
Independent job-application page. Not affiliated with, endorsed by, or operated by Alpaca. Public information as of October 2026.

Homework for my application to Alpaca Due Diligence Analyst, APAC.

How I would run due diligence on APAC partners before launch, and a working desk that checks a partner’s identity, licence, ownership and lists against public registers.

13
dated public sources: sanctions, alert lists, licence registers, FATF
43,000+
list and register entries screened in the browser, plus live GLEIF
4
partner models, each with its own document set and rules
40+
checks per partner file, each naming its source
00

Summary

The job

Clear international fintechs and financial institutions to launch on a US broker’s API: collect and review the file, reconcile it against outside sources, route questions to Compliance, AML and Legal, and keep a record that stands up later.

The hard seam

Who runs KYC. In a fully disclosed or omnibus set-up the partner screens the end customers, so the partner’s own AML programme carries the risk. The depth of the review follows the model.

The work sample

A desk that tracks five fictional partners to launch and checks any real entity live: LEI record and parents, OFAC, UK and UN lists, four APAC alert lists, four licence registers, Singapore’s ACRA register and FATF. Hits are cleared on a second identifier, near-exact names need a second reviewer, and the file is sealed with SHA-256.

TakeawayWhy it matters for partner DD
Identity is reconciled across sourcesCertificate, LEI record and licence register must name the same entity. A licence held by a sister company is a common and fixable finding.
Ownership is multiplied along every pathA person with 20% direct and two indirect stakes can hold 48.5% while each line on the register stays under 25%.
A name hit is a questionEvery hit needs a second identifier, and the reason it was cleared goes on file. Brand clones on regulator lists make this routine work.
Permission is per marketA partner licensed at home may still need a licence or an opinion for each market it sells into. That check sits next to the launch date.
01

Partner models and the KYC split

The public Broker API docs describe four set-ups. Who runs CIP and KYC decides what the due diligence file must prove.

ModelWho runs KYCWhat due diligence reviewsUS rules in play
Fully disclosedThe partner, as locally licensed broker of record. Data passes through the account API, and the broker screens every account against its own blocklist.“A thorough review of your CIP/KYC/AML program” (docs). Licence, onboarding flow, screening procedure, audit.CIP 31 CFR 1023.220; beneficial ownership 1010.230; foreign correspondent DD 1010.610; FINRA 3310, 4311
OmnibusThe partner. End customers are undisclosed; orders carry a per-customer sub-tag.AML programme in full, sub-tagging in sandbox, tax status (QI or FFI), monitoring and alert handling.1010.610; 1010.230; FINRA 3310; OFAC
OmniSubThe partner: “solely responsible for all end-customer compliance” (docs). Sub-accounts sit on the broker’s ledger without PII.“Your AML program will be reviewed during onboarding.” Plus a settlement limit sized with Treasury for post-trade netting.1010.610; 1010.230; FINRA 3310
RIA or trading appThe broker approves each account, unless the partner’s programme has been vetted.The partner’s licence to advise or market, disclosures, onboarding flow, vendors.CIP run by the broker; FINRA 2090, 2111; Notice 21-29 on vendors

Model descriptions and quotes: Broker API use cases, OmniSub, account opening. Rule texts: FINRA 3310, FINRA 4311, Notice 21-29.

02

APAC partner landscape

Partners named in Alpaca’s own announcements fall into five archetypes. Each needs a different answer to one question: is this firm permitted to offer this product to these residents?

ArchetypePublic examplesThe permission questionWhat I would ask first
Licensed incumbent brokerSBI Securities (Japan), Upstox (India), Daishin (Korea, memorandum)Usually settled at home. The work is model fit, order flow and tax status.Licence scope for foreign securities; QI or FFI status
Offshore-licensed fintechGotrade (Labuan dateline)Which residents the offshore licence lets it serve, and where its marketing reaches.Licence conditions and a market-by-market legal opinion
Licensed in a neighbouring regimePT Valbury Asia Futures (Bappebti futures licence; US stocks through OmniSub)Does the home regulator characterise the product the same way the partner does?The regulator’s written view, or a counsel opinion on product scope
Bank adding investing or cryptoGoTyme Bank (Philippines, crypto)Bank permissions and any separate crypto registration.Central bank approval, crypto licence, Travel Rule procedure
App or adviser without a broker licenceInvesting apps and RIAs across the regionThe broker runs KYC, so the review moves to marketing, disclosures and the adviser licence.Adviser licence, disclosure set, complaints process

Partners as announced on the Alpaca blog: Valbury, Gotrade, GoTyme, Upstox, SBI Securities. Market notes from the same blog: MAS in-principle approval for a Singapore entity (Sep 2026), an IDX memorandum for PALN access (Sep 2026).

03

Competitive map

Brokerage infrastructure is a short list. A partner who has onboarded elsewhere arrives with expectations about the file, so a light, clear request list is part of the product.

ProviderModelDue diligence angle
AlpacaUS self-clearing broker with Broker API and OmniSub; local entities in Japan, Europe and the Bahamas; Singapore and India in progressFour models on one file standard; partners often sell into several markets at once
DriveWealthUS broker-dealer offering embedded, fractional US equities by APIThe same core question: who owns KYC for the end customer
Interactive BrokersIntroducing broker and white-branding programmes on its own platformPartners use IBKR’s account opening; review centres on the introducing firm
Apex Fintech SolutionsUS clearing and custody for fintech brokersA clearing relationship under carrying agreements, the Rule 4311 pattern
SaxoWhite label and OpenAPI for banks and brokersBank-grade partners; heavier contract review, lighter per-customer flow
UpvestInvestment API for European fintechs under a German licenceA reference for how a regulated API firm publishes partner requirements
Futu (moomoo), TigerLicensed under their own brands in Singapore, Hong Kong, Australia and the USCompete for the same end users; also among the most cloned brands on APAC alert lists

Positioning from each provider’s public product pages, October 2026. Futu and Tiger licences checked on the SFC and MAS registers in the demo.

★

What the desk found in public data

Each row reproduces in the demo. Every source is a public register or list, dated in the Method tab.

ObservationEvidenceWeightOwner
The registration body is named differently in two placesAlpaca’s About page describes AlpacaJapan’s licence as a JSDA “Registration Number. 3024”. The FSA register lists AlpacaJapan株式会社 as 関東財務局長(金商)第3024号, a Kanto Regional Finance Bureau registration, with JSDA as an association membership. A one-line wording fix that partners’ counsel would notice.lowLegal, web
Partner brands are cloned on regulator listsThe SFC Hong Kong list carries 11 Futu or moomoo lookalike websites (Dec 2020 to Oct 2025). SC Malaysia lists clones of moomoo, Webull and an “Upstox Pro” clone (2023). A brand-impersonation baseline and the partner’s takedown route belong in the file and in periodic review.mediumDD, AML
Name-only hits need a second identifierA current partner brand scores 90% against an SFC unlicensed-entity entry listed in 2006, years before the brand existed. The desk keeps a hit open until an analyst clears it with a reason, and logs the reason.processDD
LEI records cross scripts and can omit parentsFutu Securities International (Hong Kong) holds its legal name on GLEIF in Chinese, with English only as a transliteration, and reports no consolidating parent. Identity matching has to work across scripts, and ownership comes from the share register even for listed groups.processDD
FATF lists move every plenaryJune 2026: Myanmar under a call for action with enhanced due diligence; Vietnam, Lao PDR and Nepal under increased monitoring. Partners selling into these markets need EDD and a re-check after each plenary.mediumCompliance

Demo: alpaca-dd.leverlabs.workers.dev (Live entity check tab; the Method and sources tab lists every source with its as-of date).

04

The JD duties, and my plan for each

JD lineHow I would do itShown in
Support due diligence reviews for new and existing partnersOne file per partner, one standard per model. Checks grouped as identity, licence, ownership, screening, jurisdiction, documents and consistency, each naming its source and date.Case file tab
Communicate with partners on requirements, timelines and documentsOne chaser per round: what is missing, what is stale and why, the launch date, one shared folder. Questions phrased so a partner can answer without a call.Partner chaser output
KYC, KYB, EDD, policy and onboarding flow reviews, risk assessmentsEffective ownership along every path; 25% owners and a control person evidenced; PEP and FATF triggers for EDD; the onboarding flow reviewed against the model’s KYC split.Ownership, rating
Review documents for completeness, consistency and risk indicatorsThe cross-checks a reviewer does by hand: names and numbers across certificate, LEI and register; dates that cannot all be true; signatories against the director register.Consistency checks
Track onboarding and follow up ahead of launch deadlinesPipeline ranked by launch risk: open items against days left, routed by owning team.Pipeline tab
Answer partner questions, escalate as appropriateRouting per case: Legal for licence scope, AML for programme gaps, Treasury for settlement limits, Compliance for EDD sign-off.Routing card
Work with Operations, Compliance, AML, Legal, Product and PMA shared file and memo format, so AML’s ongoing monitoring starts from the record the launch was approved on.Approval memo
Identify process gaps and recurring partner questionsTrack which documents come back stale or incomplete, and turn the top five into a pre-filled request pack per model.Document rules
Maintain records of reviews, decisions and approvalsEvery status change and cleared hit is timestamped with its reason; the memo lists every source with its as-of date.Audit trail output
05

Review standard

The decision ladder the desk applies. Any partner can be placed on it in one read of the memo.

LevelTriggerAction
stopEmbargoed country or FATF call-for-action jurisdiction in scopeDecline and record the reason
failIdentity or licence does not reconcile; a 25% owner unidentified; an open sanctions matchHold launch until resolved
EDDPEP, FATF increased monitoring, regulator alert-list matchEnhanced review and senior sign-off
warnStale or expiring documents; inconsistencies with an innocent explanationApprove with conditions and dates
unverifiedA source could not be readChecked by hand with a dated capture before approval
Fail closed

A missing list or an unreadable register leaves the check unverified. Approval needs every source answered.

One file, two teams

Pre-launch due diligence and AML’s ongoing monitoring of introducing brokers and omnibus partners share one record.

Periodic review

High risk every 12 months, medium 24, low 36, and on any trigger: new market, new product, ownership change, adverse news.

06

First 30 / 60 / 90 days

WhenWorkOutput
Days 1 to 30Learn the current questionnaire, risk scoring and approval path; shadow live APAC files; read recent partner launches and the questions partners asked most.A map of the APAC pipeline with blockers per partner.
Days 31 to 60Request packs per model and market; a register and alert-list check sheet per APAC regulator; standard chaser and memo templates agreed with Compliance and AML.Shorter first-round requests and fewer rounds per partner.
Days 61 to 90Periodic review calendar for live partners; a brand-impersonation baseline for each; recurring questions turned into partner-facing guidance with Product and PM.Files that stay current after launch, and a record ready for audit.
07

Method & sources

The demo is my own work, built for this application. Its five partners are fictional, and nothing in it is Alpaca’s process or data.

Independent homework for the Alpaca Due Diligence Analyst (APAC) role · 2026 · edwardtay.com