1. Purpose
This Anti–Money Laundering and Counter–Terrorist Financing (AML/CTF) Policy sets forth Walletes’ controls to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations.
2. Risk–based approach
We apply a risk–based approach to customers, geographies, products, and delivery channels. Controls scale with risk level and are reviewed periodically.
3. Customer Due Diligence (CDD/KYC)
- Identify and verify customers before account activation.
- Collect beneficial ownership information for legal entities.
- Screen customers against sanctions and watchlists.
4. Enhanced Due Diligence (EDD)
We perform EDD for higher–risk relationships, including source–of–funds checks and senior management approval where applicable.
5. Ongoing monitoring
We monitor transactions to identify unusual patterns and investigate alerts using case management and documented outcomes.
6. Recordkeeping & reporting
Records are retained for no less than the legally required period. Suspicious activities are reported to competent authorities when applicable.
7. Training & governance
All relevant personnel receive regular AML/CTF training. A nominated Compliance Officer oversees the program and periodic audits.