Financial crime
AML Policy
Our anti-money laundering and counter-terrorist financing framework.
Framework
Risk-based approach
Every customer, product and corridor is risk-rated at onboarding and reassessed periodically or on trigger events.
Customer due diligence
We verify identity, establish beneficial ownership above 25%, and apply enhanced due diligence to higher-risk relationships including politically exposed persons.
Sanctions screening
Customers, counterparties and payments are screened against applicable sanctions and watch lists in real time.
Transaction monitoring
Automated scenarios and behavioural models generate alerts that are investigated by trained analysts.
Reporting
Suspicious activity is reported to the relevant financial intelligence unit. We do not tip off customers about reports made.
Governance and training
A designated Money Laundering Reporting Officer owns the programme. All staff complete annual financial crime training.
Record keeping
Due diligence and transaction records are retained for a minimum of seven years.