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Compliance
FATF Guidelines

FATF Guidelines

The Financial Action Task Force (FATF) sets the global standard for AML/CFT. Lunixi maps to the FATF Recommendations most relevant to financial institutions.

The FATF obligation belongs to your institution. Lunixi does not assume it — we provide the technical infrastructure that lets you meet it: screening, monitoring, decision records and audit trail.

Recommendation 10 — Customer Due Diligence

CapabilityStatus
KYC and KYB verification at onboardingAvailable
Sanctions and PEP screeningAvailable
Continuous monitoring and re-screeningAvailable — see the note below
Adverse media screeningAvailable — see the note below

How continuous monitoring is triggered

A subject registered for monitoring is re-screened in two situations:

  • List delta (event-driven) — when a sanctions list is updated, the changed records are compared against monitored subjects
  • Periodic — an hourly job claims the records that are due
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An honest boundary: the re-screening frequency is a fixed cadence you supply at registration (daily / weekly / monthly). There is no trigger that starts a re-screen because a customer's risk score or profile changed. If you want frequency to follow risk level, you do that by updating the cadence from your side.

Adverse media screening

Adverse media screening runs over open news data and the results are passed through a classifier.

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This is not a commercial adverse-media data provider. No vendor subscription feed (World-Check, Dow Jones and similar) is integrated. Also, if the provider is not configured, the result does not silently come back "clean" — the coverage manifest is explicitly marked "not performed / source not configured". That is deliberate: a screen that never ran appearing clean is a silent compliance failure.

For detail, see Adverse Media Monitoring.

Recommendation 16 — Wire Transfers

For wire transfers, originator and beneficiary parties are carried by role in transaction screening and both parties are screened against sanctions lists. An intermediary role is also supported.

The relevant endpoint:

POST /api/v1/sanction/screening/transaction

Party and account roles (originator, beneficiary, intermediary and the corresponding account roles) are carried in the request body. The result is stored together with the identity of the list version it was screened against.

Risk-based approach

FATF's risk-based approach requires enhanced due diligence (EDD) proportional to risk. In Lunixi, the verdict is produced per screening surface rather than from a single global band table.

Transaction screening

ScoreVerdict
≥ 90block
≥ 70hold
≥ 50review
< 50allow

Name screening

ConditionVerdict
No hitsallow
Score ≥ 90block
Other hitsreview

Match bands (configurable in the database)

BandDefault threshold
Possible match65
Probable match80
Exact match92
Auto-dismissbelow 50

The risk scoring engine can additionally produce the actions allow, review, edd, hold, escalate, create_case and block.

Thresholds are configurable per tenant and per policy. The values above are defaults, adjusted to your own risk appetite.

Virtual assets and Recommendation 15 — scope

FATF R.15 requires firms to assess the risks of new technologies, including virtual assets.

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Scope statement. Virtual asset service provider (VASP) compliance is not positioned as a capability the platform offers today. Specifically:

  • The Travel Rule is not implemented — there is no IVMS 101 payload generation, no VASP counterparty directory and no transmission channel.
  • There is no on-chain analytics provider integration — no commercial chain-analytics vendor is connected.
  • A wallet address screening endpoint does exist, but the sanctioned-address list it screens against is populated from your own internal blacklist; ingestion of crypto addresses from sanctions lists is not automated.

If you have a use case that requires crypto coverage, talk to [email protected] before integrating. We are not writing "coming soon" on this page for a capability that is not in scope.

Suspicious activity reporting

Lunixi provides the infrastructure for suspicious activity reporting — evidence capture, case preparation and immutable record-keeping. Which authority you report to, within what deadline and in what format depends on your jurisdiction; the obligation and the final decision remain with your institution.

The structured reporting engine in the platform is built around UK legislation, and even there the system does not perform the submission — the compliance officer files on the authority's portal and the system records the reference and date as evidence.

For obligations in Türkiye, see MASAK.