AML & CTF Policy

Last updated: 08/04/2026

Last updated: 01/09/2025

1. Purpose and Commitment

BanQr Group Limited (“BanQr”, “we”, “us”, “our”) is committed to conducting business with the highest standards of integrity, transparency, and compliance.

This AML & CTF Policy sets out the principles and procedures we adopt to prevent our products, services, and platforms from being used for money laundering, terrorism financing, or other illicit activities.

BanQr complies with international standards, including the Financial Action Task Force (FATF) Recommendations, as well as applicable national laws and regulations in the jurisdictions where we operate (including Labuan, Malaysia, Indonesia, GCC, and the EEA).

2. Scope

This Policy applies to:

  • All BanQr directors, officers, employees, and contractors.
  • All products, services, and delivery channels (including digital banking, tokenisation, REIT management, investment platforms, and correspondent banking).
  • All customers, counterparties, and business partners engaging with BanQr.

3. Key Principles

BanQr’s AML & CTF framework is built on the following principles:

  1. Know Your Customer (KYC) & Enhanced Due Diligence (EDD)

    • Verification of customer identity, beneficial ownership, and source of funds.
    • Enhanced checks for high-risk customers, politically exposed persons (PEPs), and cross-border transactions.

  2. Risk-Based Approach (RBA)

    • Application of risk assessments to customers, products, services, delivery channels, and geographies.
    • Higher-risk categories subject to stricter controls and monitoring.

  3. Transaction Monitoring & Screening

    • Continuous monitoring of customer transactions to detect unusual or suspicious activity.
    • Screening of all parties against international sanctions lists (UN, OFAC, EU, UK, local regulators).

  4. Record-Keeping

    • Maintenance of complete and accurate records of customer information and transactions for at least 5–10 years, depending on jurisdiction.

  5. Suspicious Activity Reporting (SAR/STR)

    • Obligation to report suspicious transactions to the relevant financial intelligence unit (FIU) or regulator.
    • Zero tolerance for tipping-off customers regarding investigations.

  6. Staff Training & Awareness

    • Regular AML/CTF training for employees to identify red flags, understand regulatory obligations, and respond appropriately.

  7. Independent Audit & Oversight

    • Periodic independent audits of AML/CTF processes.
    • Oversight by BanQr’s Board of Directors and Compliance Committee.

4. Prohibited Activities

BanQr strictly prohibits relationships or transactions involving:

  • Anonymous or fictitious accounts.
  • Shell banks or unlicensed financial institutions.
  • Customers or entities engaged in illegal activities, including drug trafficking, terrorism, human trafficking, and corruption.
  • Transactions involving jurisdictions subject to comprehensive international sanctions without regulatory approval.

5. International Cooperation

BanQr works closely with regulators, correspondent banks, and law enforcement authorities globally to combat financial crime. We support cross-border cooperation in line with FATF standards and applicable treaties.

6. Roles and Responsibilities

  • Board of Directors – ultimate responsibility for AML/CTF compliance.
  • Chief Compliance Officer (CCO) – designated AML/CTF officer, responsible for oversight, reporting, and training.
  • Employees – responsible for following procedures, completing training, and escalating suspicious activity.

7. Continuous Improvement

BanQr is committed to:

  • Regularly reviewing and updating this Policy to reflect evolving legal and regulatory requirements.
  • Enhancing AML/CTF controls as new products (including digital assets, tokenised securities, and cross-border platforms) are introduced.

8. Policy Disclosure

This AML & CTF Policy is published on BanQr’s website to demonstrate transparency and commitment to compliance.

Customers, regulators, and partners may request further details on BanQr’s AML/CTF framework, including customer due diligence procedures, reporting mechanisms, and compliance governance structure.