Customer Acceptance Policy

Code	AML-011
Domain	AML / Financial Crime
Owner	Chief Compliance Officer
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD01
Review date	2027-03-31

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

Purpose

Define eligibility criteria for onboarding and establish the bank's customer acceptance framework. The bank will only onboard customers within its defined risk appetite.

Scope

All onboarding channels, customer types (individuals and entities), and origination jurisdictions (NZ and AU).

Policy statements

The bank SHALL only accept customers who can be identified, verified, and assessed for risk within its risk appetite thresholds.

Sanctioned individuals, entities, and jurisdictions SHALL be rejected at the point of screening with no path to override below Chief Compliance Officer level.

Customers whose identity cannot be verified to the minimum CDD standard SHALL be rejected; onboarding SHALL NOT proceed on an exception basis without documented approval.

High-risk customers (including PEPs and those from high-risk jurisdictions) SHALL be escalated to Enhanced Due Diligence (AML-002) before acceptance; a Compliance officer must approve before the account is activated.

The decision engine SHALL produce an explicit ACCEPT, REJECT, or REFER outcome for every onboarding application with structured reason codes and a human-readable summary.

Decision outcomes SHALL be logged with full rationale, policy references, model version, and operator identity where human review is involved.

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Satisfying modules

Module	Name	Mode	Description
MOD-153	Customer acceptance engine	GATE	No product account or facility can be activated until the acceptance engine has produced a formal ACCEPT decision — the gate is enforced at the service layer with no bypass path.

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Part of AML / Financial Crime · Governance overview Compiled 2026-05-22 from source/entities/policies/AML-011.yaml