Global finance already runs on a small number of coordinated systems, banks onboard clients and manage lifecycle through platforms like Fenergo, NICE Actimize and Oracle FCCM, they screen risk using LSEG World-Check, LexisNexis and Moody’s, they identify legal entities through GLEIF’s LEI and vLEI system, and they coordinate with each other through infrastructures like SWIFT, DTCC, Euroclear and central bank rails such as Fedwire, TARGET2 or CHAPS.
Each of these systems produces decisions every day, a bank determines that a client is onboarded, that sanctions screening is clear, that a counterparty is eligible, that a transaction is allowed. Those decisions are the real asset, but today they remain locked inside each institution, every other bank must redo the same work, and every new system such as stablecoins starts again from zero.
The Open Compliance Layer solves only one problem, it standardizes the output of those decisions and makes them portable, verifiable and enforceable across systems.
A bank continues to run KYC in Fenergo or Actimize, continues to use LSEG or LexisNexis for screening, continues to manage identity through LEI, but once the decision is made, an adapter translates that internal state into a standardized claim, that claim is signed by the institution, published into a shared attestation layer such as EAS, and becomes a piece of trusted state that can be consumed by other systems.
Onchain systems do not read documents, they read claims, a policy engine evaluates those claims and decides whether minting, transfer or redemption is allowed, the stablecoin contract simply executes.
This creates a new layer on top of existing infrastructure, SWIFT remains the messaging layer, ISO 20022 remains the language of financial messages, Chainlink ACE (Automated Compliance Engine) can act as an execution and connectivity layer, and the Open Compliance Layer becomes the missing decision layer that bridges offchain compliance and onchain execution.
The system aligns with ISO 20022 because claims can be structured using the same financial semantics already used in payment messaging, identity, party roles, account relationships and transaction eligibility can be expressed in a way that banks already understand, making integration natural rather than disruptive.
Chainlink ACE can sit below or alongside this layer, providing connectivity, data delivery and execution guarantees, while the Open Compliance Layer defines what is true and what is allowed, ACE can help enforce it across chains and systems, but it does not define the compliance state itself.
The result is simple to explain, banks keep their systems, keep their liability, keep their data, but they export their decisions into a shared, verifiable layer that controls programmable money.
This is not a new KYC system, not a new bank, not a new token standard, it is a standard way to express trust decisions so that money systems can consume them.
This is why it can be an EEA standard, it sits exactly at the coordination layer between institutions, like SWIFT or DTCC, but for compliance state.
The Open Compliance Layer is a standard that defines how regulated institutions publish and consume compliance decisions.
An institution is identified using existing systems such as LEI or vLEI from GLEIF, and binds its operational wallets to that identity through its internal authorization systems, which may already be managed through treasury platforms or custody providers.
The institution runs its normal processes using systems like Fenergo, NICE Actimize or Oracle FCCM, performs screening through LSEG World-Check or LexisNexis, and reaches a decision such as customer approved, sanctions clear, or eligible for product.
An adapter layer connects to those systems and converts that decision into a standardized claim, the adapter must be transparent, auditable and consistent across implementations, because it is the point where offchain truth becomes onchain state.
The claim contains the type of decision, the subject it applies to, the issuing institution, the validity period and the revocation status, it does not contain underlying documents or sensitive data, those remain in the bank’s systems.
The claim is published to an attestation layer such as EAS, where it can be verified, referenced and revoked.
A registry defines which institutions are allowed to issue which types of claims, for example a regulated bank can issue KYC completion, a screening provider can issue sanctions results, an issuer can assert wallet authority.
A policy engine consumes these claims and evaluates whether a given action is allowed, for example whether a wallet is eligible to receive a stablecoin, whether an issuer is authorized to mint, whether a transfer is permitted across jurisdictions.
The stablecoin contract itself remains simple and only executes actions when the policy engine approves.
The system integrates with existing financial standards such as ISO 20022 by aligning claim structures with known concepts such as party identification, account ownership, role delegation and transaction eligibility, ensuring compatibility with existing bank infrastructure.
The system can integrate with execution and oracle layers such as Chainlink ACE, which can deliver claims, trigger validations and coordinate cross-chain or cross-system enforcement, while the Open Compliance Layer remains the source of truth for compliance state.
The work required to make this real is sequential, first define a minimal set of claim types aligned with existing banking language, then define which institutions are allowed to issue those claims, then build adapters for core systems such as Fenergo, Actimize and World-Check, then implement the attestation layer using EAS, then build the policy engine that consumes claims, then connect that policy engine to a stablecoin contract, and finally onboard a small number of major banks to issue and consume claims.
The system succeeds when one institution can rely on another institution’s claim to allow a transaction without repeating the underlying compliance process, while still maintaining its own regulatory responsibility.
The Open Compliance Layer is therefore a standard for expressing and enforcing compliance decisions across financial systems, enabling existing institutions to coordinate trust in a programmable way.