AML / Financial Crime¶
| Domain ID | D03 |
| Owner | Chief Compliance Officer |
| Jurisdiction | NZ + AU |
| Applicability | Platform — SD02 delivers eIDV, CDD, KYC review, and sanctions screening. SD03 delivers the typology engine, ML behavioural scoring, alert case management, and regulatory report submission. In Track 2 tenants are the reporting entities; the platform enables their AML/CFT programme. |
Prevention, detection, and reporting of money laundering, terrorism financing, fraud, and sanctions violations.
AML programme requirement¶
Both NZ and AU require a documented, Board-approved AML programme reviewed at least annually. The programme must include: CDD procedures, transaction monitoring, suspicious activity reporting, staff training, and a designated AML compliance officer.
IFTI/CMIR thresholds¶
AU: International Funds Transfer Instructions ≥ AUD 1,000 must be reported to AUSTRAC within 10 business days. NZ: Cross-border Monetary Instrument Reports apply at NZD equivalent threshold.
Policies¶
| Code | Policy name | Status |
|---|---|---|
| AML-001 | AML/CFT Programme Policy | Draft |
| AML-002 | Customer Due Diligence (CDD) Policy | Draft |
| AML-003 | Know Your Customer (KYC) & Identity Verification Policy | Draft |
| AML-004 | Politically Exposed Persons (PEP) Policy | Draft |
| AML-005 | Transaction Monitoring Policy | Draft |
| AML-006 | Suspicious Activity Reporting Policy | Draft |
| AML-007 | Sanctions Screening Policy | Draft |
| AML-008 | Cross-Border Transfer Reporting Policy | Draft |
| AML-009 | Correspondent Banking & Payments Policy | Draft |
| AML-010 | AML Training & Awareness Policy | Draft |
Systems satisfying this domain¶
- MOD-009: eIDV verification (SD02) — GATE
- MOD-010: CDD tier assignment (SD02) — AUTO/ALERT
- MOD-011: KYC review scheduler (SD02) — AUTO/ALERT
- MOD-012: KYC audit trail (SD02) — LOG
- MOD-013: Real-time sanctions screener (SD02) — GATE/ALERT
- MOD-014: List change propagation (SD02) — AUTO
- MOD-015: False positive management (SD02) — LOG
- MOD-016: Rule-based typology engine (SD03) — AUTO/LOG
- MOD-017: ML behavioural scoring (SD03) — AUTO/LOG
- MOD-018: Alert case management (SD03) — LOG
- MOD-019: Regulatory report submission (SD03) — AUTO
Policies in this domain¶
| Code | Title | Status | Owner |
|---|---|---|---|
| AML-001 | AML/CFT Programme Policy | Draft | Chief Compliance Officer |
| AML-002 | Customer Due Diligence (CDD) Policy | Draft | Chief Compliance Officer |
| AML-003 | Know Your Customer (KYC) & Identity Verification Policy | Draft | Chief Compliance Officer |
| AML-004 | Politically Exposed Persons (PEP) Policy | Draft | Chief Compliance Officer |
| AML-005 | Transaction Monitoring Policy | Draft | Chief Compliance Officer |
| AML-006 | Suspicious Activity Reporting Policy | Draft | Chief Compliance Officer |
| AML-007 | Sanctions Screening Policy | Draft | Chief Compliance Officer |
| AML-008 | Cross-Border Transfer Reporting Policy | Draft | Chief Compliance Officer |
| AML-009 | Correspondent Banking & Payments Policy | Draft | Chief Compliance Officer |
| AML-010 | AML Training & Awareness Policy | Draft | Chief People Officer |
| AML-011 | Customer Acceptance Policy | Draft | Chief Compliance Officer |
| AML-012 | Customer Risk Rating Policy | Draft | Chief Compliance Officer |
| AML-013 | Onboarding Fraud & Identity Integrity Policy | Draft | Chief Compliance Officer |
Compiled 2026-05-22 from source/entities/risk-domains/D03.yaml