> For the complete documentation index, see [llms.txt](https://t-blocks.gitbook.io/t-blocks-documentation/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://t-blocks.gitbook.io/t-blocks-documentation/dual-rail-distribution/investor-onboarding-both-rails.md).

# Investor Onboarding (Both Rails)

T-Blocks operates a dual-track investor onboarding framework, supporting both bank-intermediated and direct subscription workflows. All onboarding routes enforce the same compliance standards regardless of the channel through which an investor subscribes.

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**Track 1 — Bank-to-Bank Subscription (Primary Route)**

The bank-to-bank route is the operationally cleanest and most efficient onboarding pathway for institutional and professional investors with established banking relationships.

The investor instructs their own bank to execute the subscription via IBAN transfer to the SubFund's designated account at Swissquote Bank Europe SA. T-Blocks provides the relevant IBAN and payment reference details to the investor. KYC/AML compliance is handled bank-to-bank: the investor's bank has already conducted its own client due diligence, and Swissquote applies its own institutional compliance layer on receipt. T-Blocks and its distribution partners are not required to conduct independent KYC in this workflow, materially reducing onboarding friction for investors operating through regulated banking infrastructure.

This route is recommended for private banks, family offices, broker-dealers, and institutional allocators with existing custody and payment infrastructure.

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**Track 2 — Direct Subscription (Manual KYC/AML)**

Where bank-to-bank infrastructure is not available or the investor is subscribing directly through T-Blocks' primary market platform, a full manual onboarding process is conducted.

The investor receives a subscription package including the relevant subscription agreement, investor declaration, and KYC documentation requirements. The investor provides identity documentation, beneficial ownership information, bank account details, and investment amount confirmation. T-Blocks conducts a risk-based KYC/AML assessment calibrated to the investor's profile, jurisdiction, and investment size. Upon approval, T-Blocks coordinates with Swissquote in advance of fund receipt to ensure that incoming transfers are pre-notified and processed without delay or compliance holds.

This track maintains full frontline compliance while preserving flexibility for investors operating outside standard institutional banking workflows.

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**Compliance Framework**

T-Blocks compliance infrastructure is aligned with CSSF regulatory standards and applies across both onboarding tracks.

| Tool / Process                      | Function                                                                                |
| ----------------------------------- | --------------------------------------------------------------------------------------- |
| Dow Jones Integrity Check           | Specialised intelligence screening, adverse media, and reputational risk assessment     |
| Sanctions screening                 | Real-time screening against EU, UN, OFAC, and UK consolidated sanctions lists           |
| PEP verification                    | Politically Exposed Person identification and enhanced due diligence triggers           |
| Adverse media monitoring            | Ongoing monitoring of negative news and enforcement actions                             |
| Risk-based assessment               | Investor risk profile calibration based on jurisdiction, structure, and investment size |
| Beneficial ownership identification | Ultimate beneficial owner verification for corporate and fund investors                 |

All compliance determinations are made by T-Blocks compliance function. Investors flagged through screening processes are subject to enhanced due diligence before any subscription is accepted. T-Blocks retains the right to decline any subscription at its discretion, without obligation to provide reasons, in accordance with its AML/CTF policy and applicable Luxembourg law.