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AML / CTF · Risk Controls

Anti-Money Laundering
Policy Overview

This AML page explains how Uninova International Bank prevents money laundering, terrorist financing, and related financial crime risks. We apply a risk-based AML/CTF framework, including customer due diligence, sanctions screening, transaction monitoring, and ongoing review. The objective is clear: support legitimate international banking activity while protecting clients and the financial system.

KYC / KYB Sanctions Screening Transaction Monitoring EDD (Higher Risk) Ongoing Reviews Suspicious Activity Escalation
Read AML Framework AML Inquiries
AML Controls Risk-Based
Controls designed for international activity.
We combine upfront due diligence with ongoing monitoring. Where risk increases, controls are strengthened through enhanced due diligence and closer review.
CDD / EDD Customer due diligence and enhanced checks when risk requires.
Monitoring Alerts, reviews, and escalation of unusual patterns.
Screening Sanctions/PEP checks and adverse media review where applicable.
Record Keeping Retention of key compliance records and auditability.
AML / CTF Program
Risk-Based Due Diligence
Ongoing Monitoring
Selective Onboarding
Overview

AML Policy Summary

Uninova International Bank maintains an AML/CTF framework designed to identify, prevent, detect, and report potential money laundering, terrorist financing, proliferation financing, fraud, and other financial crime risks. We apply controls proportionate to the nature of the client, products used, jurisdictions involved, and expected transaction behavior.

This page is provided for transparency. Detailed requirements and specific document checklists are provided during onboarding based on client profile.

01
AML Framework Risk-based principles and program elements.
02
CDD / EDD Customer due diligence and enhanced checks.
03
Screening Sanctions, PEP, and adverse media checks.
04
Monitoring Transaction monitoring and investigations.
05
Source of Funds Evidence, purpose, and legitimacy checks.
06
Reporting & Contact Escalation, confidentiality, inquiries.
Program

Our AML / CTF Framework

Our AML program is structured around core controls that work together: governance and oversight, customer due diligence, screening, transaction monitoring, escalation and reporting, record keeping, and periodic review.

Core Principles

We apply a risk-based approach — meaning we do not apply the same depth of checks for every relationship. We scale controls according to risk indicators such as jurisdiction exposure, business model, ownership complexity, expected volumes, product usage, and counterparty characteristics.

Where risk is higher, we apply enhanced due diligence (EDD), which may include additional documentation, deeper verification, and management-level approvals.

Governance Oversight, accountability, and documented procedures.
Monitoring Detect unusual behavior and request clarification as needed.
Tip: A clear explanation of your account purpose and expected activity reduces follow-up questions and helps avoid unnecessary monitoring alerts.
Due Diligence

Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

CDD is the baseline set of controls used to verify identity, understand ownership and control, and confirm that the requested account is suitable. EDD is applied when risk indicators require deeper review.

01
Identify & Verify We verify the identity of individuals and the legal existence of entities, including signatories and controlling persons.
02
Understand Ownership & Control We identify beneficial owners (UBOs) and controllers. Ownership charts may be requested for complex structures.
03
Purpose & Expected Activity We document the purpose of the account and expected transaction behavior to support smooth operations and monitoring.
04
EDD (If Required) Additional verification, deeper evidence, and approvals may be applied for higher-risk profiles or exposure.
If your structure includes multiple entities, provide a simple ownership chart from the start. This often saves days of follow-up.

Typical Triggers for EDD

EDD may be required in scenarios such as:

  • Higher-risk jurisdictions or cross-border exposure involving multiple regions.
  • Complex layered ownership structures or nominee arrangements.
  • PEP exposure or meaningful adverse media indicators.
  • Unusual transaction size/frequency relative to declared activity.
  • Industries with elevated financial crime risk depending on activity.
More Evidence Extra documents may be requested to validate funds, activity, and counterparties.
More Review EDD can increase review time due to verification and approvals.
Screening

Sanctions, PEP & Adverse Media

Screening is used to help identify exposure to sanctions restrictions, politically exposed persons (PEPs), and relevant adverse media indicators. Screening supports responsible onboarding and helps ensure ongoing activity remains aligned with regulatory expectations.

What We Screen

  • Customers, including individuals and entities.
  • Directors, controllers, and authorized signatories.
  • Beneficial owners and related parties where relevant.
  • Where applicable, counterparties and transaction references.

A screening match does not automatically mean decline — it often triggers clarification, identity verification, or EDD depending on the context.

Why Screening Matters

  • Helps prevent prohibited relationships and transactions.
  • Reduces the risk of disruption for clients and counterparties.
  • Supports transparent, auditable compliance controls.
  • Protects account integrity and the bank’s network relationships.
If you or your business has multiple names or aliases, please disclose them early so screening results can be interpreted correctly.
Monitoring

Transaction Monitoring & Review

We monitor activity to detect unusual or inconsistent patterns relative to the expected account profile. Monitoring can include rule-based triggers and manual review where appropriate.

Examples of Unusual Activity
Monitoring considers the customer’s expected activity. Examples that may trigger review include:
  • Sudden spikes in volume or large one-off transfers without an explained purpose.
  • Transactions involving high-risk jurisdictions or unexpected geographies.
  • Rapid movement of funds through the account without clear economic rationale.
  • Inconsistent counterparty patterns compared to declared business activity.
  • Transactions with unclear narratives, references, or documentation.
What Happens When an Alert Triggers
When an alert triggers, we may request clarification or supporting documents. Typical steps:
  • Review the transaction context and the customer’s profile.
  • Request explanation and supporting evidence where needed, such as invoice or contract.
  • Decide whether the activity is consistent, needs enhanced monitoring, or requires escalation.
Relationship Reviews
We may request periodic updates to maintain current information, such as:
  • Updated proof of address or corporate records.
  • Updated ownership and director information.
  • Updated expected activity, key counterparties, or business model changes.
The fastest way to clear a monitoring question is to provide a short explanation plus one piece of supporting evidence, such as an invoice or contract.

Keeping Your Account Smooth

Practical steps to reduce interruptions:

  • Use clear payment references that match invoices or contracts.
  • Inform us in advance about unusually large transactions or new geographies.
  • Keep corporate documents and signatory information updated.
  • Maintain consistency between declared activity and actual account use.
Good References Use clear payment narratives that match the underlying transaction purpose.
Advance Notice Inform the bank in advance about large transfers or new corridors where possible.
Legitimacy

Source of Funds / Source of Wealth

In international banking, it is essential to understand the origin of funds and whether it aligns with the customer’s profile. Where risk or transaction behavior requires, we may request evidence of source of funds and, in some cases, source of wealth.

Source of Funds (SOF)

SOF concerns the specific funds used in the account. Examples of evidence:

  • Salary or employment income evidence where relevant.
  • Business revenue evidence, including invoices, contracts, and bank statements.
  • Investment statements or sale agreements where applicable.
  • Tax filings or audited statements where relevant and available.

Source of Wealth (SOW)

SOW refers to how a customer’s overall wealth was accumulated over time, such as business ownership, investments, inheritance, or sale of assets. It may be requested for higher-risk cases or larger volumes.

  • Company ownership evidence or share sale documentation.
  • Longer-term investment history or statements.
  • Asset sale agreements or property records where relevant.
When providing SOF or SOW information, a short explanation plus supporting evidence is usually sufficient — we aim to keep requests practical and proportionate.
Contact

Reporting, Confidentiality & AML Inquiries

For AML or CTF related questions, onboarding clarifications, or to report concerns, please email: info@uninovabank.com.

Confidentiality

We handle compliance inquiries and documentation with confidentiality and in accordance with applicable requirements. Certain situations may require internal escalation, enhanced review, or regulatory reporting obligations.

Please avoid sending sensitive identity documents over public channels. We will provide appropriate methods during onboarding.

Important Note

This page is an informational summary of AML controls and does not constitute legal advice. Requirements and internal procedures may evolve based on regulation, risk, and product scope.

If you are already a client, you may access your portal via: Client Login.

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