Policies are not operational until approved and owned.
Name: TBD. This vacancy generates a critical blocker. Appointment requires a dated corporate resolution, written responsibilities, training record and a contact of record.
| Policy | Status | Version | Next review |
|---|---|---|---|
| AML | DRAFT | v0.1 | Upon appointment |
| KYC | DRAFT | v0.1 | Upon appointment |
| KYB | DRAFT | v0.1 | Upon appointment |
| Beneficial Ownership | NOT STARTED | — | Upon appointment |
| Sanctions | NOT STARTED | — | Upon appointment |
| Source of Wealth | NOT STARTED | — | Upon appointment |
| Source of Funds | NOT STARTED | — | Upon appointment |
| Transaction Monitoring | NOT STARTED | — | Upon appointment |
| Fraud Prevention | NOT STARTED | — | Upon appointment |
| Digital Assets | NOT STARTED | — | Upon appointment |
| Information Security | NOT STARTED | — | Upon appointment |
| Record Retention | NOT STARTED | — | Upon appointment |
| Conflicts | NOT STARTED | — | Upon appointment |
| Incident Response | NOT STARTED | — | Upon appointment |
Any trigger routes the item to COMPLIANCE REVIEW before execution.
Structure is in place to record provider, screening date, subject, result, potential match, reviewer and disposition. No screening data is fabricated; an approved provider must be integrated before any result is recorded.