AMLPolicy.

Treviya operates under the AML frameworks applicable in each jurisdiction it serves. The primary reference standards are the Financial Action Task Force (FATF) Recommendations, the UK Proceeds of Crime Act and Money Laundering Regulations, the EU Anti-Money-Laundering Directives, the Swiss Money Laundering Act and the Singapore Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act.

Where local law imposes a stricter standard than the FATF baseline, the stricter standard applies.

Treviya applies a risk-based approach to AML. Each account is assigned a risk score at onboarding based on identity verification signals, jurisdiction, declared activity and source-of-funds indicators. The risk score drives the monitoring thresholds applied to that account throughout its lifecycle.

The platform's business risk assessment is reviewed at least annually and after any material change in activity, geography or product. The most recent assessment is available to auditors and regulators on request.

All account holders are verified before any cycle authorisation. Individual members complete KYC (identity + document verification + sanctions screening). Institutional members complete KYB (entity verification + UBOs + source of funds + director identification).

Enhanced due diligence applies to higher-risk profiles, including politically-exposed persons (PEPs), accounts in higher-risk jurisdictions and accounts with material activity patterns that deviate from the declared profile. Enhanced due diligence is documented on the account record.

Full operational detail is published at /trust/kyc.

Continuous screening against UN, OFAC, EU, UK and Swiss SECO sanctions lists. Screening covers individuals, entities, ultimate beneficial owners and specified third parties. Screening runs at registration and continuously thereafter on a schedule and on material events.

Positive hits block account activation pending human review. Existing accounts with positive hits are suspended pending investigation. Sanctioned-origin goods are excluded at gate one of the six-gate curation framework, before a cycle reaches the public book.

Transaction monitoring is tuned to the commerce model: credit top-ups, cycle authorisations, settlement distributions and withdrawals. Thresholds are set by risk tier and reviewed quarterly.

Alerts are triaged by the compliance desk. False positives are documented and feed back into threshold tuning. True positives are escalated to the MLRO (Money Laundering Reporting Officer) and, where appropriate, reported to the relevant Financial Intelligence Unit.

The platform operates a structured Suspicious Activity Report (SAR) process. Where reasonable grounds exist to suspect that a transaction involves the proceeds of crime, terrorism financing or sanctions evasion, the MLRO files a SAR with the relevant authority within the statutory timeframe.

Reporting follows strict tipping-off rules. Accounts may be frozen or activity restricted during investigation without prior notice to the account holder, where law requires.

Certain goods categories are excluded from the platform as a matter of AML and sanctions policy, regulated substances, dual-use items, restricted agricultural products, wildlife products and other categories maintained on the exclusion list. Sanctioned-origin jurisdictions are excluded outright at gate one of curation. The exclusion list is reviewed quarterly.

Treviya staff undergo mandatory AML training on appointment and annually thereafter. Training is role-appropriate: compliance-desk staff receive expanded AML and sanctions training; curation, operations and commerce staff receive training focused on typologies relevant to their role. Completion is logged.

KYC and KYB records, transaction records, alert dispositions, SAR filings and related evidence are retained for a minimum of 7 years following account closure or transaction completion. Retention periods are extended where a specific investigation, legal proceeding or regulator instruction requires.

Full detail on the recordkeeping philosophy is published at /records.

The Money Laundering Reporting Officer (MLRO) holds independent responsibility for the AML programme, reports directly to the board and has authority to freeze activity, file reports and escalate matters to external authorities without internal approval.

The compliance committee meets quarterly and reviews the AML programme at least annually. Material changes are documented and shared with affected regulators. External audit of the programme is commissioned on the published cadence at /trust/audits.

AML-related queries can be directed to compliance@treviya.com. Regulator queries should be directed to the MLRO via the same address with the subject line "MLRO, [regulator name]". We respond to valid regulator queries within the applicable statutory timeframe.