LegalCompliance
AML Statement
Version 1.0 · Effective 21 July 2026 · Last updated 21 July 2026
This statement summarizes the anti-money-laundering (AML) and counter-terrorism-financing controls that Altnativ Pty Ltd applies to the Fulcrum business, with reference to the Australian AML/CTF Act 2006 and comparable frameworks in the US and EU.
1. Program summary (link to this section)
Our program combines customer verification, sanctions screening, transaction monitoring, and reporting of suspicious activity, applied in proportion to the risk of our business model.
2. Risk assessment (link to this section)
We assess money-laundering risk across customer types, geographies, and payment flows, and review the assessment when the business or the rules change.
3. Customer verification (link to this section)
We verify the identity of business customers where required, including beneficial ownership checks for higher-risk relationships, before or shortly after establishing the relationship.
4. Sanctions screening (link to this section)
Customers are screened against applicable sanctions lists at onboarding and periodically afterward. We do not do business with sanctioned parties.
5. Monitoring and reporting (link to this section)
Payment activity is monitored for unusual patterns. Suspicious activity is escalated to the designated compliance officer and reported to the relevant authority where the law requires.
6. Record keeping (link to this section)
Verification and transaction records are kept for seven years, or longer where a specific law requires it.
7. Training and review (link to this section)
Staff in relevant roles receive AML training, and the program is reviewed independently on a periodic basis. Questions: [email protected].
Related policies
This policy is issued by Altnativ Pty Ltd (ABN 52 681 839 029), trading as Fulcrum, registered in Victoria, Australia.
Websites: tryfulcrum.ai · www.altnativ.co
Legal contact: Legal and Privacy, Altnativ Pty Ltd, Victoria, Australia. Email [email protected].
© 2026 Altnativ Pty Ltd. All rights reserved.