Final AML policy pending. Summary of controls:
- Customer due diligence (CDD) at account opening
- Enhanced due diligence (EDD) for high-risk profiles
- KYC triggers — large withdrawals, suspicious patterns, jurisdictional risk
- Sanctions screening — OFAC, UN, EU lists
- Wallet risk scoring on deposits and withdrawals
- Transaction monitoring and suspicious activity reporting
- Record retention per applicable law
- Designated MLRO contact