Correspondent Banking & Payments Policy¶


Code	`AML-009`
Domain	AML / Financial Crime
Owner	Chief Compliance Officer
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD07
Review date	2027-03-25

Regulations: AML/CTF Act 2006 · AML/CFT Act 2009 · FATF 40 Recommendations ¶

Purpose¶

Govern the AML/CFT training obligations for all staff and contractors who interact with customers or handle transactions on behalf of the platform.

Scope¶

All employees, contractors, and agents of the platform in NZ and AU who perform customer-facing, transaction processing, or compliance functions.

Policy statements¶

All staff in scope SHALL complete AML/CFT awareness training before commencing customer-facing or transaction processing duties. New joiners SHALL not be permitted to perform in-scope duties until training is complete.

In-scope staff SHALL complete annual AML/CFT refresher training. Training content SHALL be updated annually to reflect current typologies, regulatory changes, and lessons from the platform's own monitoring experience.

Staff with AML/CFT specialist roles (analysts, CO, EDD reviewers) SHALL complete enhanced training appropriate to their role at least annually. Enhanced training SHALL include typology case studies and regulatory update content.

Training completion rates SHALL be tracked by the CO and reported to the Board Risk Committee quarterly. A staff member more than 30 days overdue for required training SHALL be escalated to their line manager.

The CO SHALL maintain records of training completion for all in-scope staff for a minimum of seven years.

Training materials and completion records SHALL be available to regulators on request.

Satisfying modules¶

Module	Name	Mode	Description
MOD-154	Correspondent banking risk gate	`GATE`	No payment may be routed through a correspondent bank that has not completed due diligence and received an active approval in the correspondent registry — enforced at the payment routing layer.

Part of AML / Financial Crime · Governance overview Compiled 2026-05-22 from source/entities/policies/AML-009.yaml