AML · KYC · Sanctions
Anti-money-laundering, know-your-customer, and sanctions screening.
Effective: January 1, 2026 · Reviewed annually by the Chief Compliance Officer
Aukeo maintains a written AML, KYC, and sanctions program covering every limited partner, every counterparty of material relationships, and every payee of platform funds. The program is designed to meet applicable OFAC, FinCEN, and related regulatory expectations and is administered by Compliance.
LP onboarding
All prospective LPs are screened at onboarding and on a periodic refresh cycle thereafter. Onboarding includes identity verification, source-of-funds documentation, beneficial-ownership disclosure, and sanctions screening.
Payee screening
All new payees (vendors, contractors, brokers, counterparties) are screened prior to first payment. High-risk categories are subject to enhanced due diligence.
Escalation
Suspicious activity is escalated to the Chief Compliance Officer for evaluation and, where required, reporting to appropriate authorities. Records are retained under applicable retention schedules.
Questions regarding this policy may be directed to the Chief Compliance Officer at [email protected].