AML policy
Anti-money-laundering and counter-terrorist-financing commitments.
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Placeholder — not reviewed legal wording. TODO(compliance)
This page shows the section structure of the final document. Every section is filled in by a qualified adviser before launch. Nothing on this page states a commitment, a licence or a certification, and nothing on it should be relied on.
Scope
TODO(compliance): reviewed text for “Scope”.
Governance
TODO(compliance): reviewed text for “Governance” — the officer accountable for the programme and the reporting line to the board.
Risk assessment
TODO(compliance): reviewed text for “Risk assessment” — how business, country, product and channel risk are scored.
Customer due diligence
TODO(compliance): reviewed text for “Customer due diligence” — identification, beneficial ownership, and the circumstances that trigger enhanced measures.
Sanctions and screening
TODO(compliance): reviewed text for “Sanctions and screening” — the lists screened against and the frequency of rescreening.
Monitoring
TODO(compliance): reviewed text for “Monitoring” — transaction monitoring, alert handling and escalation.
Reporting
TODO(compliance): reviewed text for “Reporting” — suspicious activity reporting and the prohibition on tipping off.
Record keeping
TODO(compliance): reviewed text for “Record keeping” — what is retained and for how long.
Training and governance
TODO(compliance): reviewed text for “Training and governance”.
Independent review
TODO(compliance): reviewed text for “Independent review” — how often the programme is tested and by whom.