Last Updated: January 1, 2025

Ledgervio Technologies Ltd. ("Ledgervio," "we," "us," or "our") is committed to maintaining the highest standards of anti-money laundering (AML) compliance and counter-terrorist financing (CTF) practices. This policy outlines our procedures for verifying customer identities, monitoring transactions, and reporting suspicious activities in accordance with applicable laws and regulations.

Our Commitment: Ledgervio maintains a zero-tolerance policy toward money laundering, terrorist financing, tax evasion, and any form of financial crime. We cooperate fully with law enforcement agencies and regulatory authorities in all jurisdictions where we operate.

1. Regulatory Framework

Ledgervio operates in compliance with the Financial Action Task Force (FATF) recommendations, the Monetary Authority of Singapore (MAS) guidelines, and applicable anti-money laundering regulations in the jurisdictions where we provide services. We adhere to international standards for customer due diligence, record-keeping, and suspicious transaction reporting.

Our AML/CFT program is designed to detect and prevent money laundering, terrorist financing, proliferation financing, and other illicit financial activities. We regularly review and update our policies to reflect evolving regulatory requirements and industry best practices.

2. Customer Due Diligence (CDD)

We implement a risk-based approach to customer due diligence. Basic wallet features are available with minimal identification requirements, while higher transaction limits and certain services require enhanced due diligence. Our CDD procedures include:

  • Identity Verification: Collecting and verifying government-issued identification documents, including passports, national ID cards, or driver's licenses.
  • Address Verification: Confirming residential address through utility bills, bank statements, or other official documentation.
  • Beneficial Ownership: Identifying and verifying the ultimate beneficial owners of corporate accounts.
  • Politically Exposed Persons (PEPs): Screening customers against global PEP databases to identify heightened-risk individuals.
  • Sanctions Screening: Checking customers against international sanctions lists, including UN, OFAC, EU, and other regulatory bodies.

3. Transaction Monitoring

We employ automated transaction monitoring systems that analyze customer transactions in real time to detect suspicious patterns and activities. Our monitoring covers:

  • Transaction velocity and volume analysis
  • Geographic origin and destination of funds
  • Structuring detection (smurfing patterns)
  • Rapid movement of funds through multiple accounts
  • Transactions involving high-risk jurisdictions
  • Unusual trading patterns inconsistent with customer profiles

Flagged transactions are reviewed by our compliance team, who determine whether further investigation is warranted. Where required, suspicious activity reports (SARs) are filed with the relevant financial intelligence units.

4. Risk Assessment

Ledgervio maintains a comprehensive risk assessment framework that evaluates customer risk based on factors including geographic location, transaction behavior, asset types, and account tenure. Customers are assigned risk ratings that determine the level of ongoing monitoring required.

High-risk customers, including those from jurisdictions with weaker AML frameworks, PEPs, and customers with complex ownership structures, are subject to enhanced due diligence measures, including more frequent transaction reviews and additional documentation requirements.

5. Record Keeping

We maintain all records related to customer identification, transaction history, and compliance activities for a minimum of five years after account closure, or as required by applicable law. Records are stored securely with restricted access to authorized compliance personnel only.

All communications with regulatory authorities, including suspicious activity reports and regulatory filings, are documented and retained in accordance with legal requirements.

6. Reporting Obligations

Ledgervio is required to report certain activities to relevant authorities, including:

  • Suspicious transactions that may involve money laundering or terrorist financing
  • Transactions exceeding regulatory thresholds
  • Cash transactions above specified limits
  • Any activity that raises reasonable suspicion of illegal conduct

We maintain strict confidentiality regarding any investigations or reports made to regulatory authorities and prohibit tipping-off customers who are subject to such reports.

7. Employee Training

All Ledgervio employees receive regular AML/CFT training commensurate with their roles and responsibilities. Training covers relevant laws and regulations, our internal policies and procedures, emerging money laundering typologies, and the importance of regulatory compliance. Our compliance team undergoes specialized advanced training on an ongoing basis.

8. Independent Audit

Our AML/CFT program is subject to independent annual audits by qualified external auditors. Audit findings are reported to senior management and our board of directors, and any identified deficiencies are addressed through corrective action plans.

9. Policy Review

This policy is reviewed annually and updated as necessary to reflect changes in regulatory requirements, business operations, and industry best practices. Material changes are communicated to all relevant stakeholders and affected customers.

10. Cooperation with Authorities

Ledgervio fully cooperates with law enforcement agencies, financial intelligence units, and regulatory authorities in their efforts to combat financial crime. We respond promptly to lawful requests for information and maintain designated points of contact for regulatory communications.

11. Contact

If you have questions about our AML/KYC policy or wish to report suspicious activity, please contact our Compliance Officer at compliance@ledgervio.com or through our Contact page.