Trust centre

Crosswire is the only party
that is not the principal.

That is the question a diligence reader actually has, so it is answered here in full: who you contract with, who holds the money, how Crosswire is paid, how providers are vetted and when they are named. This is not a certifications page. The substance is the structure.

Everything on this page is structural. There are no counts, no dates that age and no live status, because a fact that needs updating every month is a fact that will eventually be wrong here.

Contracts, funds and payment, drawn separately

Three separate relationships. Crosswire sits beside the money, never inside it.

1

Contract

Regulated services are contracted with the party that holds the licence.

Client
Your legal entity
Contracts for regulated services
Licensed provider
Holds the licence, provides the regulated service
Crosswire, separately: a coordination relationship with the client covering design, coordination and integration support. Not a regulated service, and no authority to bind either side.
2

Funds

Money moves between the client and the provider, in both directions.

Client
Sends and receives
Funds, both directions
Licensed provider
Holds and moves the money
Crosswire is not in this line. No client funds pass through Crosswire. It holds no account into which client money is paid and has no instruction rights over client balances.
3

Payment to Crosswire

The provider pays Crosswire. No Crosswire margin sits in the infrastructure price.

Licensed provider
Pays Crosswire
Pays
Crosswire
Paid by partners only
No client-to-Crosswire payment exists. There is no Crosswire fee, markup or invoice in the client's chain.

The same diagram in words

  • Contract. The client contracts directly with the licensed provider for every regulated service. The client separately has a coordination relationship with Crosswire, which is not a regulated service and carries no authority to bind either side.
  • Funds. Money moves between the client and the licensed provider, in both directions. It never passes through Crosswire. Crosswire holds no client funds, operates no account into which client money is paid, and has no instruction rights over the client's balances.
  • Payment to Crosswire. Crosswire is paid by the infrastructure partners we place you with. The infrastructure price you are quoted carries no Crosswire margin - it is the provider's own price on pre-negotiated terms. Advisory or implementation work is a separate chargeable service. Where it applies, it is quoted separately and agreed in advance, never added silently to a rate.

Most payment companies cannot draw this diagram, because they sit in the middle of the money. The separation is the point: what Crosswire cannot touch, it cannot lose, freeze or fail to return.

The questions, answered

One answer each, with the document that substantiates it.

Who contracts with the client?

The licensed provider. Every regulated service is provided by, and contracted directly with, the provider that holds the licence for it.

Crosswire's own relationship with the client covers design, coordination and integration support. It is not a regulated service, and Crosswire has no authority to bind the client or a provider, to agree regulated terms on either side's behalf, or to approve anyone for anything.

Who holds the funds?

The licensed provider. Crosswire holds no client funds, ever.

Funds move between the client and the provider in both directions. Crosswire does not receive, hold, safeguard or take possession of client money at any point, and holds no account into which client money is paid.

How is Crosswire paid, and what does that mean for incentives?

Crosswire is paid by the infrastructure partners, so the infrastructure price carries no Crosswire margin. If you want advisory or implementation work on top, that is a separate chargeable service and it is quoted and agreed in advance before any work starts.

The incentive that creates is worth stating openly rather than leaving it to be discovered: Crosswire earns only when a rail is actually placed and used, so it is paid for a stack that goes live and stays live, not for an introduction. It also means the reader should assume Crosswire has a commercial relationship with every provider it proposes, and should read a recommendation with that in mind.

The counterweight is structural. A rail that gets declined, churns or fails in production pays nothing, and the client is the party who chooses whether to proceed, on the provider's own paper.

How are providers vetted and selected?

Against a published maturity ladder, and only the top rung is assignable.

A provider moves from discovered, to commercial, to verified, to production-verified, to routable. Only routable providers are assigned to a client stack. The full ladder and the rule are set out below.

When is a provider disclosed to me?

When onboarding begins. Providers are selected, locked and disclosed at that point, and not before.

This is policy, not evasion. Before onboarding, a rail is a design choice that can still change on the basis of the entity, the vertical, the volumes and the provider's own read of the flow. Naming it early would present a candidate as a commitment. Discovery, design and pricing therefore describe rails at capability level: licensed banking, licensed card acquiring, regulated digital-asset settlement, verification.

Membership of the Crosswire network is a separate matter and is public: partners who have agreed to be named are named on the site. Which of them serves a particular client's rail is what stays closed until onboarding.

What happens if a provider does not approve me?

The rail is re-routed to an alternative in the network, and the work already done is kept.

Approval is the provider's decision alone, and no part of the Crosswire process can override it. Where a provider declines, the compliance record and the documents already collected stay in place and only the difference the alternative provider requires is requested. The client is not asked to start the file again.

Where no routable alternative fits the flow, Crosswire says so rather than proposing a rail that is not tested for it.

What information is shared with providers, and on what basis?

The information a provider needs to assess and onboard the client, shared with the client's knowledge for that purpose.

In practice that is corporate and business information, the commercial profile of the flow, and the KYB and KYC documentation the provider requires. It is shared so the provider can perform its own due diligence and price the flow. It is not sold, and it is not shared for advertising.

What are my rights over that data?

The rights the GDPR gives you: access, rectification, erasure, restriction, portability and objection, exercised by writing to us.

Retention is set out in the privacy notice, along with the legal bases we rely on and the position on international transfers. Once a provider holds data as its own controller, that provider's own notice governs it as well, and its identity is known to the client from the point onboarding begins.

The vetting ladder

The maturity model Crosswire runs providers through, published as policy.

  1. 1

    Discovered

    Not assignable

    Identified as a possible rail. The capability is claimed by the provider and nothing has been checked or tested.

  2. 2

    Commercial

    Not assignable

    Terms have been discussed and a commercial basis agreed in principle. A signed partnership sits here. Nothing has been run.

  3. 3

    Verified

    Not assignable

    Licence, legal entity and permissions checked against the public registers of the relevant authority, and the provider's documentation reviewed against the capability claimed.

  4. 4

    Production-verified

    Not assignable

    Real flow has run. Onboarding has been completed end to end, payments have settled, and the behaviour that only appears in production has been observed: failure handling, support responsiveness, reconciliation quality and how the provider behaves when something breaks.

  5. 5

    Routable

    Assignable to a client stack

    Production-verified, currently accepting the flow profile in question, and commercially in place for it. Only a routable provider is assigned to a client stack.

Only routable providers are assigned to a client stack. The reason the ladder has five rungs rather than two is that a signed partnership is not a tested rail: most of the industry publishes the second rung and lets the reader assume the fourth. A provider can be verified on paper and still be unroutable, because the flow it accepts today is not the flow in front of us.

The ladder and the rule are published. Per-provider status is not, and neither are licence verification dates: a date on a page ages the moment it is written, and a stale date reads as assurance while being worth less than none.

What Crosswire is not

Stated plainly, because implied adjacency is worse than absence.

  • Crosswire holds no financial licence and provides no regulated financial service. It is not a bank, payment institution, electronic money institution or acquirer.
  • Crosswire holds no certification of its own and does not present any provider's licence, authorisation or audit as if it were ours. Regulation sits with the party that holds it.
  • Crosswire never receives, holds or takes possession of client funds, so there is no safeguarding position to describe.
  • The terms of service and privacy notice published on this site were drafted and reviewed by external legal counsel before publication.

The legal entity

Crosswire is operated by Wernberg & Partners AB, registered in Sweden under company registration number SE5569781734, at Sveavägen 159, 113 44 Stockholm, Sweden.

Written questions on any of the above: hello@crosswirepay.com.