AML Policy
Last reviewed February 2026 — version 1.0. This document forms part of the legal framework governing your use of the PEL1 crypto compliance platform.
Regulatory framework
PEL1 operates a risk-based anti-money laundering (AML) and counter-terrorist financing (CTF) programme aligned with the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, the Sanctions and Anti-Money Laundering Act 2018, and the recommendations of the Financial Action Task Force (FATF).
Customer due diligence (CDD)
Every customer undergoes identity verification with a government-issued photo ID and biometric selfie, address verification using a recent utility bill or bank statement (≤ 3 months old), and ongoing transaction screening against sanctions lists and politically exposed person (PEP) databases via our partner analytics providers (Onfido, Chainalysis or equivalent).
Enhanced due diligence (EDD)
EDD is triggered automatically for transactions equal to or above £10,000, customers from higher-risk jurisdictions as defined by FATF, wallet activity linked to coin mixers, privacy coins or sanctioned addresses, and customers identified as PEPs or close associates. EDD requires additional documentation and compliance officer sign-off before the AML pack is issued.
Ongoing monitoring
Customer wallets and transactions are monitored throughout the relationship for unusual patterns or new risk indicators. Triggered alerts are reviewed by a compliance officer and may result in further information requests, restriction of services or termination of the account.
Suspicious activity reporting
Where we have knowledge, suspicion or reasonable grounds to suspect that a person is engaged in money laundering or terrorist financing, we will submit a Suspicious Activity Report (SAR) to the UK National Crime Agency in line with our regulatory obligations. We will not tip off the customer.
Training and governance
All PEL1 staff complete annual AML training. Our Money Laundering Reporting Officer (MLRO) reports directly to the senior management team and has unrestricted access to customer files, transaction data and partner analytics outputs.
Record keeping
We retain CDD records, transaction screening outputs and AML packs for five years after the end of the customer relationship, as required by UK MLR 2017.