Anti-Money-Laundering & Counter-Terrorist-Financing Policy

Certivo is committed to preventing its products and operations from being used to facilitate money laundering, terrorist financing, sanctions evasion or other financial crime. We take a zero-tolerance approach and expect the same standard from our customers, partners and suppliers.

This policy has two dimensions. First, it governs Certivo's own operations: the checks we perform on the commercial customers we onboard and the counterparties we transact with. Second, it describes how the platform enables our customers — banks, acquirers, PSPs, EMIs and regulated businesses — to discharge their own KYC, KYB and AML obligations. Certivo does not itself carry out regulated financial activity or provide regulated advice.

Certivo operates a risk-based program overseen by senior management. Accountability for the financial-crime program sits with a designated Compliance Officer / Money Laundering Reporting Officer (MLRO) function — described here as a role rather than a named individual — with a direct escalation line to executive leadership. Policies and risk assessments are reviewed periodically and after any material change in the business or threat landscape.

Before onboarding a commercial customer, we perform proportionate due diligence: verifying the legal entity, understanding its business and expected use of the platform, developing awareness of beneficial ownership and control, and screening the entity and its principals against sanctions and watchlists. Enhanced measures are applied to higher-risk relationships, and onboarding may be declined or exited where risk cannot be adequately managed.

Certivo screens counterparties against applicable sanctions lists, including OFAC, UN, EU and UK regimes. We do not knowingly establish or maintain relationships with sanctioned persons, entities or jurisdictions. Potential matches are investigated, and confirmed matches result in blocking and, where required, reporting to the relevant authority.

Relationships are monitored on a risk-sensitive basis throughout their lifecycle. Staff must escalate suspicious activity internally to the Compliance Officer / MLRO function, which assesses whether an external report is required and ensures it is made in the prescribed manner. Relevant records — due-diligence evidence, screening results and escalation decisions — are retained for at least five years, or longer where local law requires.

Certivo provides the tooling regulated customers use to run their own programs, including:

• identity verification (document, biometric and liveness checks via configured providers);
• sanctions, PEP and adverse-media screening against reputable data sources;
• business verification (KYB) and beneficial-ownership review;
• ongoing monitoring with re-screening and change detection;
• case management for investigation, decisioning and four-eyes review;
• immutable audit trails and configurable risk thresholds and rules.

Customers remain responsible for their own regulatory obligations, risk appetite and final decisions; Certivo supplies the infrastructure and evidence trail, not the regulated judgement.

Personnel in relevant roles receive periodic financial-crime training appropriate to their responsibilities, and the program is subject to independent review to test its design and effectiveness. Findings feed back into policy and control improvements.

Financial-crime processing is carried out consistently with our Privacy Policy and data-protection commitments. Questions about this policy or Certivo's compliance program can be directed to compliance@certivo.uk. See our Compliance & Regulatory overview for how the program maps to customer obligations.