> For the complete documentation index, see [llms.txt](https://vnx.gitbook.io/vnx-global/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://vnx.gitbook.io/vnx-global/institutional/regulatory/aml-ctf-travel-rule.md).

# AML CTF Travel Rule

*VNX's anti-money-laundering, counter-terrorist financing, sanctions, and FATF Travel Rule controls across stablecoin and payment flows.*

## Scope

This summary covers the AML/ATF programme as it applies across all VNX-authorised activities under the DABA Class M licence: stablecoin issuance and redemption (VCHF, VGBP), proprietary trading, and crypto on/off-ramp. It includes Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), sanctions screening, transaction monitoring, beneficiary verification, and Travel Rule data exchange for transfers involving virtual asset service providers.

## Principles

* **Risk-based programme** — AML/ATF controls calibrated to customer, product, geography, and channel risk, with EDD on elevated risk.
* **Sanctions integrity** — sanctions screening at onboarding and at every transaction; sender, beneficiary, and origin/destination wallet exposure are screened.
* **No co-mingling** — every customer transaction is reconciled to the relevant segregated account or wallet.
* **Travel Rule compliance** — VGBP and VCHF stablecoin transfers operate in line with FATF Travel Rule obligations for hosted and unhosted wallets.
* **Annual training and effectiveness reporting** — the Compliance Officer delivers annual AML/ATF training and an annual programme effectiveness report.

## Key controls

| Control                        | Trigger / threshold                                        | Owner                   |
| ------------------------------ | ---------------------------------------------------------- | ----------------------- |
| KYC / KYB at onboarding        | Mandatory before account use                               | Compliance              |
| Sanctions screening            | Sender, beneficiary, originating wallet, every transaction | Compliance Engine       |
| AML/ATF transaction monitoring | All flows; rule-based plus behavioural                     | Compliance              |
| Travel Rule data exchange      | Stablecoin transfers to/from VASPs and unhosted wallets    | Compliance / Operations |
| Enhanced Due Diligence         | Compliance-flagged or high-risk; tokens held pending EDD   | Compliance              |
| Wallet whitelisting            | External wallets must be whitelisted before delivery       | Compliance / Customer   |
| Daily reconciliation           | Bank balance to ledger; on-chain to ledger                 | Operations              |
| Audit log retention            | Five years minimum                                         | Operations              |
| Annual AML training            | All staff                                                  | Compliance Officer      |

## Travel Rule operating notes

Travel Rule data exchange directly affects timing on virtual-asset-funded mints and crypto-funded redemptions: average processing time for mints is approximately three hours, variable, depends on due diligence and Travel Rule. For fiat-funded mints, Travel Rule does not apply at the funding leg; it applies on token delivery to external wallets when relevant counterparty is a VASP. Whitelisted external wallets are pre-screened to reduce settlement-time impact.

## Reporting and review

The AML programme is documented in the Business Risk Assessment and reviewed at least annually. The Compliance Officer files an annual programme effectiveness report. Suspicious activity reports follow the path defined in the AML/ATF Procedure. BMA-notifiable events are escalated to the Senior Representative under DABA section 20.

## Related policies and pages

* [Regulatory Framework](/vnx-global/institutional/regulatory/regulatory-framework.md)
* [Stablecoin Specific Risks](/vnx-global/institutional/risk/stablecoin-specific-risks.md)
* [Travel Rule](/vnx-global/developer/concepts/travel-rule.md)