Anti-Money
Laundering Policy
Overview
Uninova International Bank prevents money laundering, terrorist financing, and related financial crime risks through a risk-based AML/CTF framework — including customer due diligence, sanctions screening, transaction monitoring, and ongoing review.
AML Policy Summary
Uninova International Bank maintains an AML/CTF framework designed to identify, prevent, detect, and report potential money laundering, terrorist financing, proliferation financing, fraud, and other financial crime risks.
We apply controls proportionate to the nature of the client, products used, jurisdictions involved, and expected transaction behavior. This page is provided for transparency — detailed requirements are provided during onboarding based on client profile.
Jump to Section
Use the links below to navigate directly to the relevant part of our AML framework.
Our AML / CTF Framework
Our AML program is structured around core controls that work together: governance and oversight, customer due diligence, screening, transaction monitoring, escalation and reporting, record keeping, and periodic review.
Core Principles
We apply a risk-based approach — meaning we do not apply the same depth of checks for every relationship. We scale controls according to risk indicators such as jurisdiction exposure, business model, ownership complexity, expected volumes, product usage, and counterparty characteristics.
Where risk is higher, we apply enhanced due diligence (EDD), which may include additional documentation, deeper verification, and management-level approvals.
Customer Due Diligence & Enhanced Due Diligence
CDD is the baseline set of controls used to verify identity, understand ownership and control, and confirm that the requested account is suitable. EDD is applied when risk indicators require deeper review.
Typical Triggers for EDD
EDD may be required in scenarios such as:
- Higher-risk jurisdictions or cross-border exposure involving multiple regions.
- Complex layered ownership structures or nominee arrangements.
- PEP exposure or meaningful adverse media indicators.
- Unusual transaction size/frequency relative to declared activity.
- Industries with elevated financial crime risk depending on activity.
Sanctions, PEP & Adverse Media
Screening is used to help identify exposure to sanctions restrictions, politically exposed persons (PEPs), and relevant adverse media indicators. Screening supports responsible onboarding and helps ensure ongoing activity remains aligned with regulatory expectations.
What We Screen
- Customers, including individuals and entities.
- Directors, controllers, and authorized signatories.
- Beneficial owners and related parties where relevant.
- Where applicable, counterparties and transaction references.
A screening match does not automatically mean decline — it often triggers clarification, identity verification, or EDD depending on the context.
Why Screening Matters
- Helps prevent prohibited relationships and transactions.
- Reduces the risk of disruption for clients and counterparties.
- Supports transparent, auditable compliance controls.
- Protects account integrity and the bank's network relationships.
Transaction Monitoring & Review
We monitor activity to detect unusual or inconsistent patterns relative to the expected account profile. Monitoring can include rule-based triggers and manual review where appropriate.
Examples of Unusual Activity
- Sudden spikes in volume or large one-off transfers without an explained purpose.
- Transactions involving high-risk jurisdictions or unexpected geographies.
- Rapid movement of funds through the account without clear economic rationale.
- Inconsistent counterparty patterns compared to declared business activity.
- Transactions with unclear narratives, references, or documentation.
What Happens When an Alert Triggers
- Review the transaction context and the customer's profile.
- Request explanation and supporting evidence where needed, such as an invoice or contract.
- Decide whether the activity is consistent, needs enhanced monitoring, or requires escalation.
Relationship Reviews
- Updated proof of address or corporate records.
- Updated ownership and director information.
- Updated expected activity, key counterparties, or business model changes.
Keeping Your Account Smooth
Practical steps to reduce interruptions:
- Use clear payment references that match invoices or contracts.
- Inform us in advance about unusually large transactions or new geographies.
- Keep corporate documents and signatory information updated.
- Maintain consistency between declared activity and actual account use.
Source of Funds & Source of Wealth
In international banking, it is essential to understand the origin of funds and whether it aligns with the customer's profile. Where risk or transaction behavior requires, we may request evidence of source of funds and, in some cases, source of wealth.
Source of Funds (SOF)
SOF concerns the specific funds used in the account. Examples of evidence:
- Salary or employment income evidence where relevant.
- Business revenue evidence, including invoices, contracts, and bank statements.
- Investment statements or sale agreements where applicable.
- Tax filings or audited statements where relevant and available.
Source of Wealth (SOW)
SOW refers to how a customer's overall wealth was accumulated over time, such as business ownership, investments, inheritance, or sale of assets. It may be requested for higher-risk cases or larger volumes.
- Company ownership evidence or share sale documentation.
- Longer-term investment history or statements.
- Asset sale agreements or property records where relevant.
Reporting, Confidentiality & AML Inquiries
For AML or CTF related questions, onboarding clarifications, or to report concerns, please email: info@uninovabank.com.
Confidentiality
We handle compliance inquiries and documentation with confidentiality and in accordance with applicable requirements. Certain situations may require internal escalation, enhanced review, or regulatory reporting obligations.
Please avoid sending sensitive identity documents over public channels. We will provide appropriate methods during onboarding.
Important Note
This page is an informational summary of AML controls and does not constitute legal advice. Requirements and internal procedures may evolve based on regulation, risk, and product scope.
If you are already a client, you may access your portal via: Client Login.