Protection across the full customer lifecycle.
Protection across the full customer lifecycle.
Protection across the
full customer lifecycle.
Identity is verified before trading access is granted, risk is reassessed over time, and activity that may indicate money laundering, terrorist financing, or fraud is escalated and reported where required.
Identity is verified before trading access is granted, risk is reassessed over time, and activity that may indicate money laundering, terrorist financing, or fraud is escalated and reported where required.
Identity is verified before trading access is granted, risk is reassessed over time, and activity that may indicate money laundering, terrorist financing, or fraud is escalated and reported where required.
What is money laundering?
What is money laundering?
What is money laundering?
Money laundering is how criminals turn money earned illegally — through fraud, drug trafficking, corruption, and similar crimes — into money that looks clean enough to spend, invest, or bank without drawing attention. It typically moves through three stages:
Money laundering is how criminals turn money earned illegally — through fraud, drug trafficking, corruption, and similar crimes — into money that looks clean enough to spend, invest, or bank without drawing attention. It typically moves through three stages:
Placement
Illicit cash enters the financial system, often broken into smaller amounts to avoid detection.
Placement
Illicit cash enters the financial system, often broken into smaller amounts to avoid detection.
Layering
Funds are moved through multiple accounts, assets, or borders to obscure where they came from.
Layering
Funds are moved through multiple accounts, assets, or borders to obscure where they came from.
Integration
The now "clean" money re-enters the economy as seemingly legitimate income or wealth.
Integration
The now "clean" money re-enters the economy as seemingly legitimate income or wealth.
Why it matters
Left unchecked, laundered money doesn’t just enrich criminals—it has wider consequences for society by funding trafficking, corruption and, in the worst cases, terrorism; distorting markets and weakening trust in financial institutions; and disadvantaging legitimate businesses that must compete with enterprises supported by dirty money.
Why it matters
Left unchecked, laundered money doesn’t just enrich criminals—it has wider consequences for society by funding trafficking, corruption and, in the worst cases, terrorism; distorting markets and weakening trust in financial institutions; and disadvantaging legitimate businesses that must compete with enterprises supported by dirty money.
Why it matters
Left unchecked, laundered money doesn’t just enrich criminals—it has wider consequences for society by funding trafficking, corruption and, in the worst cases, terrorism; distorting markets and weakening trust in financial institutions; and disadvantaging legitimate businesses that must compete with enterprises supported by dirty money.
What BTSE's programme covers
What BTSE's programme covers
What BTSE's programme covers
These principles come together as a set of controls that operate across the full customer lifecycle — from the moment someone applies for an account, through every transaction they make, to the records and reports BTSE is obligated to keep.
These principles come together as a set of controls that operate across the full customer lifecycle — from the moment someone applies for an account, through every transaction they make, to the records and reports BTSE is obligated to keep.
Customer identification & verification
KYC checks confirm customer identity before granting access, with Enhanced Due Diligence (EDD) applied to higher-risk customers, including PEPs.
Customer identification & verification
KYC checks confirm customer identity before granting access, with Enhanced Due Diligence (EDD) applied to higher-risk customers, including PEPs.
Transaction & ongoing monitoring
Transaction patterns are continuously analysed to assess risk and detect suspicious behaviour, since risk can change after onboarding.
Transaction & ongoing monitoring
Transaction patterns are continuously analysed to assess risk and detect suspicious behaviour, since risk can change after onboarding.
Risk assessment & management
BTSE takes a risk-based approach, applying controls proportionate to the risk a customer, product, or jurisdiction presents.
Risk assessment & management
BTSE takes a risk-based approach, applying controls proportionate to the risk a customer, product, or jurisdiction presents.
Compliance & governance
A senior Compliance Officer oversees compliance with relevant laws, regulations, and guidance.
MLRO & governance
A senior Money Laundering Reporting Officer (MLRO) oversees compliance with relevant laws, regulations, and guidance.
Suspicious activity reporting
Suspicious activity is escalated internally and reported to the relevant law enforcement or financial intelligence authorities.
Suspicious activity reporting
Suspicious activity is escalated internally and reported to the relevant law enforcement or financial intelligence authorities.
Record keeping
Customer identification, transaction, and supporting records are retained per applicable law to support audits and investigations.
Record keeping
Customer identification, transaction, and supporting records are retained per applicable law to support audits and investigations.
The programme lifecycle
The programme lifecycle
The programme lifecycle
Rather than a one-off check at sign-up, these controls run as a continuous cycle — screening feeds monitoring, monitoring feeds reporting, and every stage is recorded and fed back into how risk is assessed.
Rather than a one-off check at sign-up, these controls run as a continuous cycle — screening feeds monitoring, monitoring feeds reporting, and every stage is recorded and fed back into how risk is assessed.
How monitoring works in practice
How monitoring works in practice
How monitoring works in practice
Every transaction is assessed across two complementary dimensions — behavioural and on-chain — then weighed against the customer's risk profile to determine a proportionate response.
Every transaction is assessed across two complementary dimensions — behavioural and on-chain — then weighed against the customer's risk profile to determine a proportionate response.
Every transaction
Complementary monitoring dimensions
Behavioural analysis
Blockchain analysis
Risk-based weighting
Proportionate response
Continuous review & improvement
Every transaction — assessed on an ongoing basis.
Behavioural analysis — account, activity, and pattern signals assessed against expected behaviour.
Blockchain analysis — on-chain provenance and exposure to known illicit activity.
Risk-based weighting — signals weighed alongside each customer’s risk profile, set at onboarding and kept current.
Proportionate response — higher risk receives greater scrutiny, ranging from monitoring to review, hold, or escalation.
Continuous review & improvement — controls tested, tuned, and updated as risks, typologies, and regulations evolve.
Behavioural and blockchain analysis run in parallel — a concern raised by either dimension can prompt a review on its own.
Every transaction
Complementary monitoring dimensions
Behavioural analysis
Blockchain analysis
Risk-based weighting
Proportionate response
Continuous review & improvement
Every transaction — assessed on an ongoing basis.
Behavioural analysis — account, activity, and pattern signals assessed against expected behaviour.
Blockchain analysis — on-chain provenance and exposure to known illicit activity.
Risk-based weighting — signals weighed alongside each customer’s risk profile, set at onboarding and kept current.
Proportionate response — higher risk receives greater scrutiny, ranging from monitoring to review, hold, or escalation.
Continuous review & improvement — controls tested, tuned, and updated as risks, typologies, and regulations evolve.
Behavioural and blockchain analysis run in parallel — a concern raised by either dimension can prompt a review on its own.
Every transaction
Complementary monitoring dimensions
Behavioural analysis
Blockchain analysis
Risk-based weighting
Proportionate response
Continuous review & improvement
Every transaction — assessed on an ongoing basis.
Behavioural analysis — account, activity, and pattern signals assessed against expected behaviour.
Blockchain analysis — on-chain provenance and exposure to known illicit activity.
Risk-based weighting — signals weighed alongside each customer’s risk profile, set at onboarding and kept current.
Proportionate response — higher risk receives greater scrutiny, ranging from monitoring to review, hold, or escalation.
Continuous review & improvement — controls tested, tuned, and updated as risks, typologies, and regulations evolve.
Two dimensions.
One risk view.
Two dimensions.
One risk view.
Two dimensions.
One risk view.
Behavioural and on-chain analysis run in parallel. A concern raised by either dimension can prompt review on its own, then be weighted alongside the customer's current risk profile.
Behavioural and on-chain analysis run in parallel. A concern raised by either dimension can prompt review on its own, then be weighted alongside the customer's current risk profile.
Behavioural and on-chain analysis run in parallel. A concern raised by either dimension can prompt review on its own, then be weighted alongside the customer's current risk profile.
BEHAVIOURAL
BEHAVIOURAL
Account & activity signals
Account & activity signals
Account & activity signals
Patterns assessed against expected customer behaviour and product use.
Patterns assessed against expected customer behaviour and product use.
ON-CHAIN
ON-CHAIN
Blockchain provenance
Blockchain provenance
Blockchain provenance
Wallet exposure and connections to known illicit or sanctioned activity.
Wallet exposure and connections to known illicit or sanctioned activity.