The purpose of this policy is to establish a robust compliance framework for COOWN. This framework ensures that all anti-money laundering (AML) and counter-terrorist financing (CTF) activities are governed by national regulations, with Regional Operators responsible for implementing and enforcing these requirements. While the Foundation supports this effort by providing adaptable technical infrastructure and global support services, the AML Officers that are engaged by the Regional Operators are taking care of the operative implementation.
The Foundation is responsible for developing and maintaining the COOWN platform and setting global AML/CTF standards. The General Manager of the Foundation ensures that all global templates are current and accessible. The Foundation also maintains the jurisdiction-wide sanctions list and sources of sanctions list, and provides training materials and data normalization resources.
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The Executive Manager of each Regional Operator is accountable for maintaining an AML policy for the jurisdictions served, based on the global template and adapted as needed to comply with jurisdiction-specific rules. The Executive Manager is also responsible for ensuring that all standard operating procedures (SOPs) are implemented and kept up to date, including onboarding, transaction monitoring, sanction monitoring, and reporting.
Regional Operators must also ensure all customer data is recorded in the jurisdiction-specific customer database, and that operational activities are logged in the national list of flags processed database, sanctions check log, and high-value transaction log. Consistency and compliance across these processes are the responsibility of the Executive Manager.
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