Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Compliance Policy
Alea Group AG
Effective Date: 1 November 2025
Geneva, Switzerland
Introduction
Alea Group AG is committed to preventing money laundering, terrorist financing, and the evasion of international sanctions. Our framework aligns with Swiss and international regulations, including:
- Federal Act on Combating Money Laundering and Terrorist Financing (AMLA, RS 955.0)
- FINMA Anti-Money Laundering Ordinance (AMLO-FINMA)
- Requirements of our Self-Regulatory Organisation (SO-FIT)
- Standards set by the Financial Action Task Force (FATF)
Legal Status
Alea Group AG is registered in Switzerland under CHE-445.359.847 and headquartered in Geneva.
As a financial intermediary under Article 2(3) AMLA:
- We are an active member of SO-FIT.
We operate as a Payment Service Provider (PSP) and, in some cases, a Virtual Asset Service Provider (VASP).
Our AML framework is overseen by a designated AML Compliance Officer.
Compliance contact:
Customer Due Diligence
Before onboarding any client, we conduct full Know Your Customer (KYC) checks. These include:
- Identification and verification of natural and legal persons
- Identification of beneficial owners and controlling persons
- Verification of business purpose and relationship intent
- Collection of required AML declarations (e.g., Form A, Form K)
Depending on the service, we may use digital tools such as video identification, NFC passport readers, or bank verification.
Risk Classification and Screening
Each client is assigned a risk level based on jurisdiction, business structure, political exposure, and expected activity volume.
We screen all clients against:
- SECO sanctions lists
- EU, UN, and OFAC (SDN) lists
- PEP databases
- Adverse media sources
Any positive match is escalated to the AML Compliance Officer.
Transaction Monitoring
We monitor all fiat and digital asset transactions using automated and manual methods. Alerts are generated for:
- Large or irregular transactions
- Structuring or layering patterns
- Transactions linked to mixers, sanctioned wallets, or darknet services
For digital assets, blockchain analytics tools are used.
We also comply with the FATF Travel Rule where applicable.
Suspicious Activity and Reporting
If we suspect criminal activity, terrorist financing, or false identification:
- We fulfil obligations under Article 9 AMLA.
A Suspicious Activity Report (SAR) may be filed with MROS.
Account freezing may occur without client notification (no tipping-off permitted).
We cooperate with FINMA, MROS, SO-FIT, and other authorities when required.
Business Refusals and Termination
Alea may reject or terminate relationships without notice if a client:
- Fails to provide required identification
- Is linked to high-risk or non-cooperative jurisdictions
- Operates activities outside our risk appetite (e.g., unregulated gambling, anonymous payment services)
- Is connected to sanctioned entities, shell banks, mixers, or high-risk financial platforms
Staff Training and Governance
All relevant staff receive mandatory AML/CTF training at least annually.
We follow a three-lines-of-defence model:
- Business units (initial checks)
- Compliance (monitoring & oversight)
- Audit and external review
The AML Compliance Officer reports annually to the Board of Directors.
Recordkeeping and Data Security
We retain:
- Identification data
- Transaction history
- Compliance documentation
Retention period: minimum 10 years under AMLA and AMLO-FINMA.
Records are held in secure, encrypted databases located in Switzerland or approved EEA jurisdictions.
Third Parties and Outsourcing
Any outsourced services (onboarding, screening, infrastructure) must comply with Swiss AML law.
Providers are vetted, contractually bound, and monitored.
Alea retains full legal responsibility.
Sub-outsourcing is not allowed without written approval.
Contact and Reporting
To report suspicious activity or compliance concerns:
Reports are handled confidentially under Swiss legal protections.
Final Notes
Alea Group AG regularly updates its AML/CTF framework based on:
- Legal changes
- FATF updates
- Internal risk reviews
Our goal is to maintain high standards of integrity, transparency, and compliance.