CLARIFY

Compliance

AML Policy

Last updated: May 2026

Clarify applies risk-based AML controls aligned with FATF guidance for virtual asset service providers.

1. Screening scope

Incoming deposits and associated wallet addresses are screened using integrated AML providers (including AMLBot in sandbox or production mode).

Screening covers sanctions exposure, darknet markets, mixers, stolen funds, scams, and other high-risk typologies.

2. Risk scoring

Each transaction receives a risk score and status classification (GREEN, YELLOW, RED).

GREEN: low risk, eligible for automated processing. YELLOW: elevated risk, operator review required. RED: high risk, rejection or escalation.

3. Operator review

Operators may approve, reject, or request additional information before payout.

Multimodal processing above configured thresholds requires manual operator handling.

4. Sandbox vs production

During MVP testing, AML checks may run in provider sandbox mode — real API integration with test credentials and limited billing.

Production mode uses live AML databases and is required before serving real client funds at scale.

5. Reporting

Suspicious activity may be reported to competent authorities where legally required.

Clients receive clearance reports for completed transactions where applicable.