AML and sanctions statement

1. Who is responsible

• Licensed partners run their own anti-money-laundering programmes for the regulated services they provide: they approve customers, apply their controls, appoint their own compliance officers and report to the authorities.
• Licensed institutions running their own programme do the same under their own permissions.
• Axora Payments LLC provides the verification, screening, monitoring and case-management tooling, and operates workflows on their instructions. Its controls cannot be switched off by a client.

2. Due diligence on clients

Every client is reviewed before onboarding: its ownership and control, its licences and registrations, its business model, products, markets and expected activity, and its own compliance controls. Higher-risk clients get enhanced review. Reviews are repeated periodically and when something changes.

3. Due diligence on end users

• Identity verification of individuals, with document and liveness checks.
• Verification of businesses, including directors and beneficial owners.
• Enhanced due diligence for higher-risk customers, such as politically exposed persons.
• Ongoing due diligence, with information refreshed according to risk.

4. Screening and monitoring

• Sanctions and politically-exposed-person screening at onboarding and on an ongoing basis.
• Screening of payments and their counterparties.
• Blockchain analytics screening of wallet addresses and transfers for crypto-asset services.
• Transaction monitoring with risk-based rules, and review of alerts by trained staff.

5. Travel Rule

For crypto-asset transfers, originator and beneficiary information is collected, checked and exchanged where the law requires, in line with FATF Recommendation 16 and, in the EU, Regulation (EU) 2023/1113. Transfers that lack the required information can be held or returned.

6. Sanctions

Programmes do not serve sanctioned persons or comprehensively sanctioned jurisdictions, and apply the sanctions lists required by the law that applies to each partner and client. Further restrictions apply where a partner requires them. Attempts to evade sanctions lead to the actions in the Acceptable use policy.

7. Reporting and records

Unusual activity is investigated. Where the law requires, the obliged provider reports suspicious activity to its financial intelligence unit and does not tell the customer about the report. Records of due diligence and transactions are kept for the period the law requires.

8. Governance

Policies and controls are documented, reviewed at least once a year and when laws or risks change, and staff who onboard and review customers are trained for their role.

9. Due-diligence requests

Partners and banks can ask for our due-diligence questionnaire and supporting documents through their usual contact or at legal@axorastack.com.