AML/CTF Policy Framework - Concept

1. Introduction

To establish a compliance framework where:

Foundation's Role:
- Develops and maintains the COOWN platform
- Provides configurable AML tools (KYC/KYB, monitoring, case management)
- Maintains global reference lists (sanctions, restricted jurisdictions)
- Offers sandbox environment for testing only
Regional Operators' Role:
- Fully responsible for compliance in their jurisdictions
- Must adapt platform to local legal requirements
- Serve all end-customers (Foundation has no direct customer relationships)

Component	Foundation	Regional Operator
Legal Basis	Provides template policies	Must validate against local law
KYC/KYB	Offers basic workflows	Implements country-specific requirements
Monitoring	Supplies rule templates	Customizes thresholds and red flags
Reporting	Generic SAR templates	Adapts to local FIU requirements
Audits	Technical documentation	Conducts regulatory compliance audits

KYC for Individuals:
- Regional Operators determine accepted IDs (e.g., Aadhaar in India)
- Set risk classification rules per national standards
KYB for Entities:
- Implement local UBO thresholds (e.g., 25% in EU, 10% in UAE)
- Apply jurisdiction-specific EDD measures