Legal

AML & CTF Policy

The Vision Bank Ltd (company number 16767315) operates a risk-based anti-money-laundering and counter-terrorist-financing program aligned with FCA guidance and FATF recommendations. Authorised by the Financial Conduct Authority — licence reference 487395.

Last updated: 29 June 2026

1. Customer due diligence (CDD)

All clients complete identity verification, address verification, and politically-exposed-person and adverse-media screening before transacting. Enhanced due diligence applies to higher-risk clients and corridors.

2. KYC tiers

Account features unlock progressively as verification deepens (identity → address → liveness → source-of-funds). Limits are enforced at each tier and reviewed periodically.

3. Source of funds / wealth

For larger deposits, withdrawals, or risk-flagged activity, we request documentary evidence of the origin of funds and accumulated wealth. Funds may be held until evidence is reviewed.

4. Sanctions screening

Clients, counterparties, and on-chain addresses are screened against OFAC, EU, UN, and UK sanctions lists at onboarding and continuously thereafter.

5. Transaction monitoring

Fiat and on-chain transactions are monitored in real time by a rules-engine combined with KYT analytics covering exposure to mixers, darknet markets, ransomware, theft, and scam clusters.

6. Case management

Alerts are triaged by trained analysts, escalated to the MLRO where required, and documented in an immutable case log.

7. Reporting

Suspicious activity is reported to the relevant Financial Intelligence Unit in accordance with local law. We may not be able to inform you of any such report (tipping-off prohibition).

8. Record keeping

KYC, transaction, and case records are retained for the period required by law (typically 5–10 years after the end of the relationship).

9. Training and governance

All staff complete annual AML/CTF training. The MLRO reports to the Board and oversees policy, testing, and independent review.

10. Prohibited activity

We do not service mixers, darknet markets, unlicensed money-service businesses, or clients located in comprehensively sanctioned jurisdictions.

Questions

Talk to compliance.

This document is informational and does not constitute legal advice. For clarifications, email compliance@thevisionbank.com or open a ticket from your account.