Purpose
Provide one integrated financial-crime and integrity process covering AML/CTF/CPF, anti-bribery and corruption, KYC/CDD, sanctions, transaction monitoring and escalation.
Policies Implemented
- POL-AML-001 AML CTF CPF Compliance Manual
- POL-ABC-001 Anti-Bribery and Corruption Manual
- POL-KYC-001 KYC and CDD Manual
Trigger
The process starts when a client, counterparty, employee, transaction, wallet, third party, alert, unusual activity, integrity concern or regulatory change requires financial-crime assessment or action.
High-Level Flow
Identify person and activity -> assess identity, ownership and risk -> screen and monitor -> investigate alerts and integrity concerns -> restrict or escalate where required -> decide reporting and remediation -> retain evidence -> review effectiveness and recalibrate.
Inputs
- Client, beneficial-owner, representative, employee and counterparty information.
- Transaction, wallet, payment, source-of-funds and expected-activity information.
- Sanctions, adverse-information, blockchain analytics and monitoring results.
- Gifts, conflicts, third-party, bribery and corruption information.
- Regulatory requirements, typologies and risk assessments.
Outputs
- Approved, restricted, rejected or escalated relationships and activity.
- Documented monitoring, investigation and disposition records.
- FIU, sanctions, management and regulatory decisions where applicable.
- Current risk ratings, due diligence and remediation evidence.
Roles
- Compliance and the MLRO own financial-crime standards, escalation and reporting decisions.
- Operations performs approved onboarding, screening, monitoring and evidence steps.
- Business owners provide complete information and implement restrictions.
- Technology maintains approved screening, monitoring and evidence systems.
- Management oversees risk without overriding mandatory legal or Compliance decisions.
- Independent assurance tests design and operating effectiveness.
Operating Model
This is a primary BCMS process. It links directly to policies, requirements, procedures, controls and systems. It does not contain or depend on subordinate PRC objects. Detailed operating steps remain in the linked PROC objects.
Relationships
- Architecture decision: ADR-003 Flatten Compliance Process Architecture
- AML policy: POL-AML-001 AML CTF CPF Compliance Manual
- Integrity policy: POL-ABC-001 Anti-Bribery and Corruption Manual
- KYC policy: POL-KYC-001 KYC and CDD Manual
Assurance
- Design status: implemented through approved AML, ABC and KYC policies.
- Operating status: inherited from the linked procedures and controls.
- Evidence status: defined in the linked controls and systems.
- Overall status: implemented primary process; operating effectiveness remains subject to linked issues and assurance.
History
- 2026-07-26: Created as one of the five active processes in the flattened BCMS process architecture.