Risk-based approach
Emlo applies a risk-based approach to customer risk assessment, onboarding, and transaction monitoring. Controls are designed to be proportionate to actual risks, business complexity, counterparties, geography, and customer profile.
Screening and transaction monitoring
Control design includes sanctions screening, PEP screening, customer and transaction monitoring, risk-based review thresholds, and escalation procedures for unusual or high-risk activity.
Suspicious activity escalation
Where suspicion arises, matters are escalated through documented internal procedures, with compliance and MLRO functions acting as central points for review and reporting decisions.
AML/CFT statement
Emlo Financial Services Limited maintains a public commitment to proportionate AML/CFT controls for institutional remittance and compliance activity. The control model is designed around customer due diligence, screening, monitoring, escalation, record-keeping, and accountable compliance oversight.