Purpose
Anti money laundering, usually shortened to AML, is the set of controls that stop a financial service being used to move the proceeds of crime or to fund it. It sits behind identity verification: KYC establishes who somebody is, and AML is concerned with what happens on the account afterwards.
This page describes the shape of that programme and what it means for you as somebody using Crpko.
What the programme covers
An AML programme in this industry is built from the same parts wherever it is run:
02.1 Customer due diligence
- Verifying identity before an account is used fully
- Understanding the nature of the activity expected on an account
- Applying additional scrutiny where a customer or an activity presents higher risk
02.2 Screening
- Checking customers against sanctions lists
- Checking for politically exposed persons and for adverse media
- Repeating those checks over time rather than only at sign up
02.3 Monitoring and reporting
- Watching account activity for patterns that do not fit
- Investigating what the monitoring surfaces
- Reporting to the relevant authority where required
- Keeping records of customers and activity for the period the law requires
What this means for you
For almost everybody it means verifying once and nothing further.
Sometimes we may need to ask where funds came from, or for information about a particular transaction. That is a normal part of the controls above and not an accusation. Where we are able to explain why we are asking, we will.
We may restrict or suspend an account where we are required to, and there are situations where we are not permitted to explain the reason. That is a genuine constraint on us rather than a preference.
Not published yet
Several parts of this belong here as specifics rather than as descriptions, and they are not published on this page yet: our regulatory registration, the thresholds that trigger additional checks, how long records are kept, and the named officer responsible for the programme.
They are omitted because a compliance figure that reads as published and turns out to be wrong is worse than an acknowledged gap. They will be filled in here rather than quietly appearing somewhere else.