Onboarding Fraud & Identity Integrity Policy¶


Code	`AML-013`
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 ¶

Purpose¶

Prevent fraudulent onboarding by detecting and blocking synthetic identities, document fraud, device-based fraud signals, and velocity patterns at the point of application.

Scope¶

All onboarding processes and channels.

Policy statements¶

The bank SHALL apply fraud detection controls at the point of every onboarding application before an acceptance decision is produced.

Device fingerprinting SHALL be performed on every application. Applications from emulators, proxied devices, or devices already associated with high-risk patterns SHALL be escalated or blocked.

Duplicate detection SHALL identify applications that share identity attributes, device fingerprints, or behavioural patterns with known or suspected fraudulent prior applications.

Velocity checks SHALL detect anomalous application rates across device, IP, identity attribute clusters, or geographic segments and shall apply configurable thresholds.

Applications exhibiting high-confidence synthetic identity patterns (composite attributes consistent with fabricated identities) SHALL be rejected without manual review path.

Document and biometric evidence SHALL be assessed for consistency; a material mismatch between presented document and biometric SHALL result in rejection unless escalated through the EDD path with explicit Compliance approval.

Fraud event outcomes SHALL be recorded with full evidence reference so that patterns can be analysed, models retrained, and legal referrals made where required.

Satisfying modules¶

Module	Name	Mode	Description
MOD-055	Onboarding fraud scoring engine	`GATE`	Device, velocity, duplicate, and synthetic identity signals evaluated at the point of application; BLOCK / REVIEW / ALLOW outcome gates the onboarding decision orchestrator.

Part of AML / Financial Crime · Governance overview Compiled 2026-05-22 from source/entities/policies/AML-013.yaml