The programme
Six pillars of our AML/CTF framework
01
Governance & the MLRO
A Money Laundering Reporting Officer and Nominated Officer own the programme, with clear escalation and senior-management reporting.
02
Customer due diligence
Risk-rated KYC/KYB at onboarding, with enhanced due diligence for higher-risk customers, PEPs and complex structures.
03
Ongoing monitoring
Real-time and retrospective transaction monitoring with typology-based rules tuned per corridor.
04
Screening
Sanctions, PEP and adverse-media screening at onboarding and on every transaction.
05
Reporting
Internal escalation to the MLRO and timely SAR/STR filing to the relevant financial intelligence unit where required.
06
Training & assurance
Role-based training for all staff and periodic independent review of programme effectiveness.
Risk-based approach
How we assess and respond to risk
Customer risk
Each customer is risk-rated on geography, product, channel and behaviour; ratings drive CDD depth and review frequency.
Enhanced due diligence
EDD applies to PEPs, high-risk jurisdictions and unusual activity, including source-of-funds and source-of-wealth checks.
Suspicious activity
Staff escalate concerns to the MLRO, who determines whether to file a SAR/STR and whether to apply restrictions.
Record-keeping
CDD records, monitoring alerts and reports are retained for the statutory period and available to regulators.