AML Compliance Approach
This Anti-Money Laundering (AML) Compliance Approach outlines the principles, controls, and procedures that Eteri Digital Management Ltd applies in its own operations and recommends to clients in order to prevent money laundering, terrorist financing, fraud, and other illicit activities.
The company provides consultancy on crypto payment processing and applies a risk-based approach when advising clients on compliance with applicable AML, counter-terrorist financing (CTF), and sanctions regulations.
Eteri Digital Management Ltd acts solely in a consultancy capacity. The company does not operate a payment or crypto processing platform, does not hold or transfer client funds, and does not act as an obliged entity on behalf of its clients. Where obligations under AML legislation arise, they rest with the regulated entity concerned.
1. Compliance Approach
The company is committed to responsible business conduct and maintains internal policies and procedures designed to prevent its consultancy services from being used in connection with financial crime.
Advisory methodologies and internal compliance measures are regularly reviewed and updated in line with regulatory expectations, risk exposure, and operational requirements.
2. Risk-Based Framework
A risk-based approach underpins the frameworks we design with clients to identify, assess, and manage risks associated with counterparties, transactions, jurisdictions, and services.
Risk factors typically addressed include:
- counterparty profile and business activity
- geographic location and jurisdiction risk
- transaction patterns and volume
- use of high-risk assets or services
Enhanced due diligence is recommended in higher-risk scenarios.
3. Customer Due Diligence (KYC)
We advise clients on designing customer due diligence procedures appropriate to their business model, counterparty base, and jurisdiction.
Within such procedures, clients are typically advised to obtain:
- government-issued identification
- proof of address
- identity verification, including biometric checks where required
- business or corporate documentation (where applicable)
- source of funds or source of wealth information
Eteri Digital Management Ltd applies proportionate due diligence to the corporate counterparties it engages with, and may decline or discontinue an engagement where the outcome is unsatisfactory.
An engagement may be restricted, suspended, or terminated if due diligence requirements are not met.
4. Transaction Monitoring
We advise clients on building transaction monitoring frameworks capable of detecting suspicious activity on an ongoing basis.
Such frameworks may include:
- analysis of transaction patterns and behaviour
- blockchain analytics and wallet screening
- detection of unusual or high-risk activity
- alert generation and manual review
Decisions to delay, reject, or block a transaction rest with the client operating the relevant service. The company does not monitor, process, or intervene in third-party transactions.
5. Sanctions and Screening
We advise clients on screening counterparties and transactions against applicable sanctions lists and watchlists.
Recommended controls address situations where:
- a counterparty is located in a restricted or sanctioned jurisdiction
- a counterparty appears on a sanctions list
- a transaction involves a high-risk or prohibited counterparty
The company applies equivalent screening when selecting its own clients and may decline or terminate an engagement on that basis.
6. Prohibited Activities
The company strictly prohibits the use of its consultancy services in support of illegal or high-risk activities, including but not limited to:
- money laundering or terrorist financing
- fraud or financial manipulation
- sanctions evasion
- use of stolen or unauthorised funds
- transactions related to illegal goods or services
Any suspected violations may result in immediate suspension or termination of the engagement.
7. Reporting and Cooperation
Statutory obligations to report suspicious activity to competent authorities rest with the regulated entity concerned. We advise clients on establishing internal escalation and reporting procedures that meet applicable requirements.
The company cooperates with regulators, law enforcement agencies, and authorised bodies in matters relating to financial crime prevention, where required by applicable law.
Compliance-related inquiries may be addressed to compliance@eterix.ge.
8. Record Keeping
We advise clients on retaining records related to verification, transactions, and compliance checks for the periods required by applicable law.
Records generated in the course of our advisory engagements are retained in line with applicable legal and professional requirements, and may be used for audit, investigation, and regulatory purposes.
9. Internal Controls
The company maintains internal controls designed to ensure compliance, including:
- staff training and awareness programs
- restricted access to sensitive data
- monitoring and audit procedures
- incident response and escalation processes
10. Updates
This AML Compliance Approach may be updated from time to time to reflect changes in legal requirements, risk environment, or operational practices.
The latest version will be available on the website. Questions relating to this document may be sent to compliance@eterix.ge.
Eteri Digital Management Ltd, a company registered in Georgia. Registered address: Georgia, Tbilisi, Saburtalo district, Bakhtrioni street, N 22, apartment N75.