1. Customer identification
Every member must provide a government-issued ID, proof of address, and a live selfie. Business accounts must additionally submit registration documents, beneficial-ownership disclosures, and director identification.
2. Risk scoring
Each account is assigned a risk score based on geography, product usage, expected transaction volume, and source of funds. Higher-risk accounts undergo Enhanced Due Diligence (EDD).
3. Ongoing monitoring
Transactions are monitored continuously against rule-based and behavioral models to detect structuring, unusual velocity, sanctioned counterparties, and other red flags.
4. Sanctions screening
All members and counterparties are screened against OFAC, UN, EU, and UK sanctions lists at onboarding and on a recurring basis. Matches are blocked and escalated.
5. Suspicious activity reporting
Where required, FAAB files Suspicious Activity Reports (SARs) and other regulatory notifications. We do not disclose to the subject that a report has been filed.
6. Record keeping
KYC records, transaction histories, and investigation files are retained for the period required by law (typically 5–7 years) in encrypted storage with restricted access.
7. Training & governance
FAAB staff complete AML training at onboarding and annually. The program is overseen by a designated compliance officer who reports independently to leadership.
8. Reporting concerns
If you suspect financial crime on our platform, contact compliance@faabfunds.com. Reports may be made anonymously.
Questions about this policy?