Governance
An AML/ATF compliance program and compliance officer function are under development in advance of operations.
Compliance framework
A compliance-led operating model under development.
This page is a public summary of intended controls. It is not ALTA’s internal AML/ATF manual and does not represent that operations have commenced.
KYB & UBO
The intended framework identifies and verifies legal entities, directors, beneficial owners and controlling persons.
Screening
Planned controls include sanctions, politically exposed person (PEP) and adverse-media screening.
Source of funds
Payment activity may require evidence of the origin of funds, commercial purpose and expected counterparties.
Monitoring & EDD
Risk-based monitoring and enhanced due diligence are planned for higher-risk sectors, corridors, goods, counterparties and transaction patterns.
Trade-related review
Origin of goods, end use, export controls and potential dual-use exposure may require supporting evidence and escalation.
Records & reporting
Record keeping and suspicious transaction reporting processes are being designed to meet applicable legal obligations.
Restrictions
Prohibited jurisdictions and restricted industries will be controlled through policy, screening and escalation.
Important
Final policies, controls and service availability remain subject to legal review, regulatory requirements, banking arrangements and operational readiness.
Risk-based review
Information should explain the complete commercial picture.
Who is paying whom, for what, from where, and why?
Those questions guide the planned onboarding and transaction-review approach. Additional information may be required, and a business or transaction may be declined.