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Anti-Money Laundering Policy

Comprehensive AML/CFT policies and procedures for preventing financial crime

Anti-Money Laundering (AML) Policy


Last updated: January 24, 2026


Stackbit is committed to preventing money laundering, terrorist financing, and other financial crimes. This AML Policy outlines our comprehensive approach to detecting, preventing, and reporting suspicious activities.


Our Commitment


We are dedicated to:


  • Compliance with all applicable AML/CFT laws and regulations
  • Detection of suspicious transactions and activities
  • Prevention of money laundering and terrorist financing
  • Reporting of suspicious activities to relevant authorities
  • Training of staff and partners on AML requirements

    • Regulatory Framework


    Our AML program complies with:


  • FATF Recommendations: Financial Action Task Force standards
  • Local Regulations: National Bank of Cambodia and other jurisdictional requirements
  • International Standards: UN, OFAC, EU sanctions and watchlists
  • Industry Best Practices: Fintech AML guidelines and standards

    • Scope


    This policy applies to:


  • All transactions processed through Stackbit services
  • Agent network operations and partners
  • Platform integrations and API users
  • All employees, contractors, and service providers

    • Risk-Based Approach


    We employ a risk-based approach to AML compliance:


  • Customer Risk Assessment: Tiered risk levels based on customer profiles
  • Transaction Monitoring: Real-time analysis of transaction patterns
  • Geographic Risk: Enhanced due diligence for high-risk jurisdictions
  • Product Risk: Risk assessment for different service types

    • Customer Due Diligence


    We conduct thorough customer due diligence (CDD) to verify customer identity and assess risk.


    Identity Verification


  • Government-issued ID: Passport, national ID, or driver's license
  • Proof of address: Utility bill or bank statement
  • Phone number verification: SMS or call verification
  • Biometric verification: Facial recognition for enhanced KYC

    • Risk-Based Tiers


  • Low Risk: Residents of low-risk jurisdictions, standard transactions
  • Medium Risk: Non-resident customers, higher volumes, business customers
  • High Risk: High-risk jurisdictions, PEPs, complex structures

    • Watchlist Screening


    We conduct comprehensive screening against global sanctions and watchlists:


  • OFAC, EU, UN Sanctions: Office of Foreign Assets Control and international sanctions
  • PEP Lists: Politically exposed persons databases
  • Adverse Media: Negative news and reputation databases
  • Law Enforcement: Wanted persons and criminal databases

    • Transaction Monitoring


    We monitor all transactions in real-time to detect suspicious patterns:


  • Automated Monitoring: Real-time analysis using machine learning
  • Pattern Detection: Structuring, smurfing, and unusual patterns
  • Velocity Checks: Transaction frequency and amount analysis
  • Red Flags: Indicators of money laundering or terrorist financing

    • Suspicious Activity Reporting


    We file Suspicious Activity Reports (SARs) when we detect:


  • Suspected money laundering activities
  • Terrorist financing indicators
  • Structuring or smurfing activities
  • Transactions involving sanctioned entities

    • Training and Compliance


    All employees, agents, and partners receive comprehensive AML training:


  • Initial Training: Within 30 days of onboarding
  • Ongoing Training: Annual refresher and updated training
  • Specialized Training: For high-risk roles and compliance team
  • Assessment: Knowledge tests and certification

    • Record Keeping


    We maintain comprehensive records of all AML-related activities:


  • Customer Records: KYC documentation and verification records
  • Transaction Records: All transactions with supporting documentation
  • Monitoring Records: Alert logs and investigation records
  • Retention: Minimum 5-7 years per regulatory requirements

    • Contact


    For AML inquiries: aml@stackbit.com


    For suspicious activity reporting: sar@stackbit.com