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Legal

Financial Crime and AML

The controls the platform provides, and where responsibility for using them sits.

Last updated 21 August 2026

What counts as evidenceThree rows. A control described in a document is unticked; a control enforced by code and one refused by the database are ticked. Only the second and third are evidence that something holds.Described in a documentEnforced by codeRefused by the database

Before you rely on this

This document is a drafting framework prepared for a platform that is not yet trading. It has not been reviewed by qualified counsel in any jurisdiction, and it must be before it is relied upon by anybody.

This page describes controls the software makes available. It is not a statement that the operator is a regulated firm, and it does not discharge any obligation that falls on a customer using the platform.

1. Where responsibility sits

Customer due diligence on an investor is the obligation of the firm with the customer relationship — normally the issuer or its appointed administrator. The platform provides the tooling to perform and evidence it. It does not perform it, and using the platform does not transfer the obligation to us.

2. Controls the platform provides

  • Identity and business verification workflows, with the decision, the evidence and the decision-maker recorded together.
  • Screening case management for sanctions, politically-exposed persons and adverse media, against whichever provider a customer connects.
  • Risk rating recorded per investor, with the reasons for the rating.
  • Periodic review scheduling driven by risk rating and elapsed time.
  • An append-only audit trail that cannot be edited by anybody, including us.
  • Segregation of duties: the person who requests a sensitive action cannot be the person who approves it.

3. What the platform does not do

  • It does not decide whether to accept a customer.
  • It does not file a suspicious activity report. That obligation, and the prohibition on tipping off, rest with the reporting firm.
  • It does not supply sanctions or PEP data. A screening provider must be connected, and until one is, no screening takes place.

Before this page is published

The highlighted terms above are facts about a specific legal entity that this draft does not know. Each must be supplied, and the whole document reviewed by qualified counsel, before anybody relies on it.

  • MLRO name and contact, where the operator is required to appoint one
  • SUPERVISORY BODY for anti-money-laundering purposes, and the registration number
  • CONFIRMATION of which obligations fall on the operator and which on the customer