The Vision Corporation Holdings Ltd (company number 16767315) operates a risk-based anti-money-laundering (AML) and counter-terrorist-financing (CTF) programme aligned with international standards, including the recommendations of the Financial Action Task Force (FATF).

This framework applies to all clients, employees, and third parties acting on behalf of The Vision Bank. We act as an agent and distributor under regulated partners. We do not directly hold an EMI or VASP licence. All regulated financial and crypto services are delivered through our licensed partner institutions. Product availability varies by jurisdiction.

The purpose of this framework is to protect the platform, our clients, and the wider financial system from money laundering, terrorist financing, sanctions evasion, and related financial crime.

• Comply with applicable AML/CTF laws and regulations
• Detect and deter misuse of the platform
• Cooperate with regulators, law enforcement, and financial intelligence units
• Protect legitimate clients from being exposed to illicit activity

Controls are applied proportionately to risk. We assess each relationship and transaction against a defined set of factors and calibrate due diligence, monitoring, and approvals accordingly.

Higher-risk situations trigger additional verification, closer monitoring, or senior sign-off. Lower-risk activity is handled with proportionately lighter controls.

• Jurisdiction of the client, counterparty, and activity
• Customer profile, including business type and beneficial ownership
• Transaction behaviour and expected activity
• Products and services used
• Delivery channels and onboarding method
• Blockchain exposure and on-chain counterparty risk

All clients complete identity verification before transacting. CDD combines identity, address, and screening checks and is refreshed periodically.

• Government-issued identity document and liveness check
• Address verification where required by law
• Politically-exposed-person (PEP) and adverse-media screening
• Beneficial-ownership identification for corporate clients

EDD applies where risk factors indicate a higher level of exposure. Additional evidence, senior sign-off, and closer monitoring may be required before activity is permitted or continued.

• Clients or counterparties in high-risk jurisdictions
• PEPs, close associates, and family members
• Unusual or complex ownership structures
• Activity that is unusual for the client's profile
• Higher-value or higher-risk transactions

PEPs are individuals entrusted with prominent public functions, and their close associates and family members. Because of their position, PEP relationships require enhanced measures.

• Screening at onboarding and on a continuous basis
• Senior management approval before establishing or continuing the relationship
• Enhanced source-of-funds and source-of-wealth checks
• Ongoing monitoring calibrated to the elevated risk

Source of Funds refers to the origin of the specific funds used in a transaction. For larger deposits, withdrawals, or risk-flagged activity, we may request documentary evidence. Funds may be held until evidence has been reviewed.

• Employment income (payslips, employment contract)
• Business income (financial statements, tax filings)
• Investment proceeds (broker statements, contract notes)
• Property sales (sale agreement, completion statement)
• Inheritance (probate documents, solicitor correspondence)
• Other lawful sources, evidenced appropriately

Source of Wealth refers to how a client's overall wealth was accumulated over time. SoW is typically requested for higher-risk relationships, PEPs, and larger accounts, and is distinct from SoF for a single transaction.

The documentation requested depends on the circumstances and may combine multiple evidence types to establish a plausible overall picture of accumulated wealth.

Clients, counterparties, and on-chain addresses are screened against consolidated sanctions lists including UK OFSI, EU, US OFAC, and UN designations. A positive match blocks the interaction pending review.

• Onboarding screening for individuals, entities, and beneficial owners
• Continuous re-screening as lists and customer data change
• Wallet-address and counterparty screening for on-chain activity
• Geographic restrictions for comprehensively sanctioned jurisdictions

Know-Your-Transaction (KYT) analytics assess the on-chain history of counterparties and transactions. Signals are combined with account context to score risk and prioritise review.

• High-risk wallet exposure (direct and indirect)
• Sanctioned addresses and designated entities
• Theft and hack indicators
• Ransomware exposure
• Scam and phishing cluster indicators
• Mixer, tumbler, and privacy-service exposure
• Cross-chain behaviour and bridging patterns

Fiat and on-chain transactions are monitored in real time by a rules engine combined with KYT analytics and behavioural baselines. Alerts are triaged by trained analysts and escalated to the MLRO where required.

• Rules covering thresholds, velocity, structuring, and geography
• Behavioural baselines specific to the client's profile
• On-chain exposure signals from KYT analytics
• Immutable case log with full audit trail

Compliance activity does not end at onboarding. Reviews take place throughout the client relationship to keep information current and controls relevant.

• Periodic KYC refresh based on risk rating
• Reviews triggered by significant changes in activity
• Re-screening on updated sanctions and PEP lists
• Reassessment on changes in beneficial ownership for corporate clients

Where we form a suspicion that funds or activity may be linked to money laundering, terrorist financing, or other financial crime, we report to the relevant Financial Intelligence Unit in accordance with local law.

Reporting obligations may limit what we can disclose. In particular, tipping-off rules generally prohibit us from informing a client that a report has been made or an investigation is underway.

Compliance activity is part of maintaining a secure and lawful platform. Clients may occasionally receive requests connected to due-diligence or monitoring reviews.

• Confirm your identity or provide updated identification
• Update personal or business information
• Provide additional documentation supporting activity
• Explain unusual, unexpected, or higher-value transactions

The following activity is prohibited on the platform. Attempted use for these purposes will result in restrictions, account closure, and — where required by law — reporting to the appropriate authority.

KYC records, transaction records, and case files are retained for the period required by applicable law — typically five to ten years after the end of the client relationship or completion of the transaction, depending on the jurisdiction.

Records are stored securely with appropriate access controls and are made available to competent authorities on lawful request.

Every employee is trained to recognise money-laundering and terrorist-financing risks in their role. Training is refreshed annually and after material regulatory change.

• Structured onboarding for all new joiners
• Annual refresher covering AML, sanctions, and financial-crime typologies
• Role-specific training for onboarding, monitoring, and customer-facing teams
• Testing to confirm understanding and identify gaps

A dedicated Money Laundering Reporting Officer (MLRO) is responsible for the AML/CTF programme. The MLRO operates independently and reports to the Board.

• Board oversight of the AML/CTF programme and risk appetite
• Independent MLRO with direct access to the Board
• Internal controls testing on a risk-based cadence
• Independent reviews to validate programme effectiveness
• Clear staff responsibilities and escalation paths

Third parties that support the AML/CTF programme are assessed before onboarding and reviewed regularly. This includes custody providers, banking partners, and technology vendors that touch client data or transactions.

• Custody providers assessed for segregation, controls, and financial strength
• Banking partners reviewed for AML, sanctions, and operational resilience
• Technology providers evaluated for security posture and data handling
• Ongoing vendor reviews with defined escalation for material issues

We respond to lawful information requests from regulators, financial intelligence units, law enforcement, and tax authorities in accordance with applicable law and data-protection safeguards.

This framework is reviewed at least annually and after any material regulatory or business change. Updates are approved by senior management and communicated to relevant staff.