Which rule answers which obligation

A direct match on a sanctions list freezes the funds pending the MLRO's decision; nothing is returned automatically.

No policy, built-in or custom, can turn a direct designation or an issuer freeze into ALLOW.

An address the stablecoin issuer has frozen goes to the MLRO.

No provision requires checking issuer freezes. It is mapped to the risk monitoring it supports; issuers often freeze on law-enforcement request.

A high-risk or rejected verdict from your crypto processor freezes the funds pending the MLRO.

Relying on the processor's screening does not move the responsibility; FATF Recommendation 17 keeps it with you.

A medium-risk processor verdict sends the event to human review.

A claimed deposit that is not found, reverted or unconfirmed on chain goes to human review.

Mapped to the requirement that records reconstruct the real transaction; a deposit that is not on chain cannot be recorded as received.

When a mandatory check could not run, the decision is a technical hold, never ALLOW.

No policy, built-in or custom, can turn a failed mandatory check into ALLOW.

If the active policy cannot be read, the decision is a technical hold.

A wallet already registered by another of your customers goes to human review.

A behaviour signal (shared wallet, pass-through, structuring) goes to human review; behaviour never blocks alone.

With every mandatory check complete and processor evidence on file, the event is allowed and the evidence is recorded.

Confirms the claimed transfer exists, succeeded and paid the stated address.

Screens the address against the official sanctions lists at decision time.

Reads the issuer's freeze state on chain at decision time.

Beyond what is required; mapped to the virtual asset risk assessment it feeds.

Records whether ownership of a self-hosted wallet was evidenced.

Records whether your processor supplied evidence for its verdict, not just a verdict.

Not available on the public baseline; filled only by a commercial provider you connect.

Not available on the public baseline; filled only by a commercial provider you connect.

Applies the behaviour rules to the customer's own funding history.

Records whether originator and beneficiary information was received with the transfer.

The event proceeds; the receipt records what was and was not checked.

A case opens for a human to look before funds move on.

Funds are held for the MLRO, who decides whether to report; releasing them takes two people.

Checks could not be completed, so the event does not proceed until they are.

Every decision is kept as a signed, append-only record that can be replayed later.