AML / CTF Policy

Public summary. The full programme document is held internally and provided to regulators and counterparties on request.

Framework

Averra Pay operates an AML / CTF programme aligned with FATF Recommendations and applicable national transpositions (UK MLR 2017 as amended, EU AMLD framework moving to EU AMLR / AMLA, US BSA via FinCEN).

KYB and KYC

All customers undergo Know-Your-Business onboarding; ultimate beneficial owners are identified and verified. Risk-based KYC applies to end-users where Averra Pay issues named accounts (vIBANs).

Sanctions screening

Continuous screening against OFAC, UN, EU, HMT and MAS consolidated lists. Refresh on list updates; transaction-level sanctioned-party checks on all flows.

Transaction monitoring

Rule-based and risk-tier-based monitoring. Suspicious activity is escalated to the MLRO and reported to the relevant Financial Intelligence Unit where threshold is met.

Governance

A named Money Laundering Reporting Officer (MLRO) owns the programme. Independent annual audit. Board-level oversight.

Report a concern

Suspected money laundering, sanctions evasion, or fraud involving Averra Pay: compliance@averrapay.com.