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  1. Customer’s name is checked against sanction list every time there is transaction being executed (buy or sell) if there is a match a transaction is not processed( operator doesn’t send coins or operator doesn’t dispense cash). Customer’s crypto address is also checked against sanction list( OFAC list contains also crypto addresses). Sanction list check can be also initiated manually by operator on the identity. Operator also receives notification each time sanctioned identity/address tries to perform transaction.

  2. Exact implementation of OFAC list checking is here: https://github.com/GENERALBYTESCOM/batm_public/tree/master/server_extensions_extra/src/main/java/com/generalbytes/batm/server/extensions/extra/watchlists/ofac

    1. only first name and last name is used. If user provides only one word it is considered to be last name. when user provides middle name then middle name is not used. Name entry is also tested against gibberish entry.

  3. In case of OFAC list is implementation following:

    1. when last name matches but first name doesn’t match the score is 50%. When both last name and first name matches score is 100%. When only last name is provided and matches the score is 100%. When crypto address fully matches (case insensitive) score is 100%. 100% = fail, 50% = passes.

  4. Answered in later point.

  5. Data are downloaded from Treasury every 24hours from here: https://www.treasury.gov/ofac/downloads/sanctions/1.0/sdn_advanced.xml we believe it is the latest version.

  6. Every 24 hours. ATM server scans always locally downloaded sanction list.

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AML/KYC

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Blacklists

Blacklists are a static method of blocking customers & wallet addresses. The lists may be customized based on your experiences or information received from a third-party source.

CAS Blacklists are described in context here: https://generalbytes.atlassian.net/l/c/UrqHJcpr