Note. Counsel-drafted; skeleton structure below.
1. Statement of posture
znobia operates under a sanctions and anti-money-laundering framework consistent with the requirements of UK regulation, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), HM Treasury / OFSI financial-sanctions regimes, and the UK Bribery Act 2010.
2. Sanctions regimes screened
UK (OFSI), EU, US (OFAC), UN, and other jurisdictionally applicable regimes. Counterparties screened at onboarding and at refresh intervals; positive screening hits escalated to the MLRO.
3. AML / KYC
Risk-based customer due diligence on every counterparty. Enhanced due diligence on higher-risk counterparties, including (without limitation) PEPs, counterparties in higher-risk jurisdictions, and counterparties involved in higher-risk digital-asset activities.
4. Digital-asset specific
Counterparty wallet-screening on engagement and at intervals. Chain-analytics provider: [TBD]. Sanctioned-address policy: no transactions; counterparty re-screening on triggered events.
5. Reporting
Suspicious activity reports filed with the National Crime Agency as required. MLRO contact: [name] · [email protected].
6. Training and review
All staff receive AML and sanctions training at onboarding and annually thereafter. The MLRO reviews the framework annually and reports to the board.