Most provider pages list countries. A due diligence call is about what you can hold, what you can convert, who holds the money and what you can reconcile. These twelve questions cover that. Each has a good answer and a red flag, and the answers for Modality are given where they are public.
The twelve questions
| # | Ask | A good answer | A red flag |
|---|---|---|---|
| 1 | Which currencies can I hold a balance in? | A list of currencies, by name | A country count, or "we support" without a list |
| 2 | Are pairs converted directly, or through USD? | Direct pairs, with the number | "Most routes" or silence on the route |
| 3 | Do I see the rate before I commit, and how long is it held? | A quote shown first, with a stated hold time | The rate is known only after execution |
| 4 | Which institution holds client money, and what is its role in my contract? | The institution's name and its role for each service | Only the provider's own name |
| 5 | Who is my contract counterparty for each service? | One clear entity per service | A group name without entities |
| 6 | What happens to the fiat leg at weekends and holidays? | A rail-by-rail answer | "Always instant" |
| 7 | Which digital assets can I settle in? | A list | A category name |
| 8 | Can I get a statement per currency with stable IDs? | Yes, with your reference on every line | Totals only |
| 9 | What are the limits and onboarding steps per corridor? | Written limits and a named process | Case-by-case, no document |
| 10 | How is travel rule data carried with a transfer? | A described data flow | "We handle compliance" |
| 11 | Can I withdraw balances and export history if I leave? | Yes, with a stated process | No exit terms |
| 12 | What happens when a payment is returned? | A reason code, a time frame and an owner | A support email |
How Modality answers where the answer is public
1. Currencies held. Modality holds balances in 36 account currencies:
- Americas: USD, CAD, MXN, BRL, BMD
- Europe: EUR, GBP, CHF, SEK, NOK, DKK, PLN, CZK, HUF, BGN
- Middle East: AED, SAR, QAR, KWD, BHD, OMR, JOD, ILS, TRY
- Asia-Pacific: JPY, CNY, HKD, SGD, INR, THB, AUD, NZD
- Africa: ZAR, KES, MUR, MAD
Access depends on onboarding, eligibility and review.
2. Direct pairs. 630 direct pairs between the 36 currencies. EUR to TRY is one conversion, not two. See direct currency pairs.
3. Rate before commitment. The rate is known before the payment is committed. See quote then execute.
4 and 5. Who holds the money. Modality is a technology services provider — not a bank and not a licensed money transmitter. Payment, custody and exchange services are provided by regulated financial institution partners under their own licences and authorisations. Ask any provider, including us, to name the institution for each service in your contract.
6. Weekends. Settlement runs 24/7. The fiat leg depends on the rail at each end. See which legs close at the weekend.
7. Digital assets. Seven: RLUSD, USDC, USDT, BTC, ETH, SOL and XRP.
Why questions 1 and 2 come first
A country count describes where a customer can be onboarded. A currency list describes what a customer can hold. The two numbers answer different questions, and only the second tells you whether a payment between two currencies needs a third. See 100 countries, 3 currencies.
Why question 10 is not optional in Europe
The European Banking Authority said on 4 July 2024 that Regulation (EU) 2023/1113 extends the travel rule to crypto-asset service providers, so information about the originator and beneficiary has to travel with a crypto-asset transfer. Its guidelines apply from 30 December 2024. A provider that cannot describe this data flow is a provider you will end up explaining to your auditor.
How to use the list
Send the twelve questions in writing. Score each answer green, amber or red. Two reds on questions 1 to 4 are a reason to stop. Reds on questions 8 to 12 are a reason to negotiate terms before you sign. To test your own pairs against the list of currencies, use the pair checker. For how Modality describes its security and operating model, see Trust & Security.
Frequently asked questions
Why ask for a currency list and not a country list?
A country list says where the provider can onboard you. A currency list says what balances you can hold and convert.
Should I ask who holds client money?
Yes. Ask for the institution's name for every service in your contract, and check it with the institution's own supervisor, not with the provider.
What if a provider answers every question green?
Ask for the answers in the contract.
Sources
- European Banking Authority, press release on travel rule guidelines, 4 July 2024 eba.europa.eu
- FATF, Virtual Assets and VASPs — Recommendation 15 updates fatf-gafi.org
- Modality coverage sheet, July 2026 (36 account currencies, 7 digital assets, 630 direct pairs).
Check your own pairs: .
Get a quote