How It Works

Identity Information Collection

When a user is registered as an account holder, we collect their identity information.

3rd Party Screening

Each time an action such as account holder creation, account creation, or transaction is initiated, we screen that user against the applicable sanctions lists to ensure the user’s actions do not violate any applicable sanctions program.

User Alert

If we receive an alert during the sanctions screening process indicating a potential sanctions list match:

1. The user’s request is held or prevented and added to our Legal & Compliance team’s review queue;
2. The Legal & Compliance team will review the alert and determine whether the alert is valid.

False Positives

If the Legal & Compliance team determines that the alert does not match the user (a “false positive”), the hold or prevention on the request will be released.

Valid Alert

If the Legal & Compliance team determines that the alert is valid:

1. The request is cancelled;
2. We freeze the assets in their wallet and prevent any further actions from that user and any transactions to and from their wallet; and
3. We contact the applicable governmental authority and inform them of the match to their sanctions list.