Compliance framework

A compliance-led operating model under development.

This page is a public summary of the intended controls of ALTA MONEY SERVICES LTD. (the “Company”). It is not the Company’s internal AML/ATF manual and does not represent that operations have commenced.

Governance

The Compliance Officer has been appointed. The AML/ATF compliance program and its supporting operational controls are under development in advance of operations.

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 documentation

Invoices, contracts, counterparties, goods, origin, destination and shipping routes 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

Service availability depends on applicable regulatory requirements, approved banking arrangements, an approved operating model 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.