MTD-FRM-01 · Financial Crime Framework (v1.2)
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mtd-frm-01-financial-crime-framework.md
4425 bytes · owner Head of Financial Crime (MLRO)as at 2026-02-12 (approval date)
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38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363Allocated to assessments
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1.1 This Framework establishes how Mittenda organises the prevention of financial crime: the disciplines in scope, the accountability for each, the documents through which each is governed, and the assessment and appetite that direct them.
1.2 It is approved by the Board and reviewed at least annually. The policies and Standards made under it carry its requirements into each discipline; nothing in this Framework relieves any obligation under them.
Mittenda Limited owns and operates this Framework: it sets how the firm organises its own financial crime prevention, including its PSP/CASP activities in scope of EU 2023/1113. Governance document, so evidence, not a board-set criterion.
2.1 The disciplines of the portfolio are: money laundering and terrorist financing; financial sanctions and restrictive measures; fraud; bribery and corruption; and the facilitation of tax evasion.
2.2 Each discipline is governed by the document named in §4.1 and owned by the role named there. Where a matter falls within more than one discipline, the Head of Financial Crime (MLRO) determines the lead discipline.
Defines the scope of Mittenda Limited's financial crime portfolio (incl. ML/TF and sanctions, which the transfer-of-funds duties serve) and the MLRO's role in allocating matters. Owned by the firm.
3.1 The Board owns this Framework and approves it annually, together with the Risk Appetite Statement.
3.2 The Head of Financial Crime (MLRO) is accountable for the portfolio and reports quarterly to the Board on the state of each discipline against the appetite set in the Risk Appetite Statement.
3.3 The Risk and Compliance Committee approves the Standards made under the AML/CTF Policy and oversees their operation and the measures reported under them.
Sets Mittenda Limited's own governance and accountability for financial crime (Board, MLRO, Risk and Compliance Committee), relevant to the firm's internal policies, procedures and controls for EU 2023/1113. Owned and performed by the firm.
4.1 The governing document and owner for each discipline:
Discipline Governing document Owner Money laundering and terrorist financing AML/CTF Policy Head of Financial Crime (MLRO) Financial sanctions and restrictive measures AML/CTF Policy §11; Sanctions Screening Standard Head of Financial Crime (MLRO) Fraud Fraud Policy Head of Financial Crime (MLRO) Bribery and corruption Anti-Bribery and Corruption Policy Head of Compliance Facilitation of tax evasion AML/CTF Policy, as a predicate offence to money laundering Head of Financial Crime (MLRO) 4.2 Each governing document is approved as §3 provides, is reviewed at least annually, and carries a document-control record in the MTD scheme. The Standards and Procedures beneath them are recorded in the document register at Appendix A.
Mittenda Limited's own document hierarchy and ownership for each discipline, including the AML/CTF Policy and Sanctions Screening Standard that govern controls in scope of EU 2023/1113. Owned by the firm.
5.1 A business-wide financial crime risk assessment is performed at least annually, and on any material change to the business, covering each discipline of the portfolio across Mittenda's customers, products and services, delivery channels, geographies and transaction types.
5.2 The assessment is produced by the Head of Financial Crime (MLRO) and approved by the Board. Its conclusions calibrate the Standards and the risk-based procedures beneath them. For money laundering and terrorist financing it constitutes the assessment required by the AML/CTF Policy §3.
Describes the business-wide risk assessment Mittenda Limited performs (MLRO produces, Board approves) and how it calibrates the firm's risk-based procedures. Activity owned and performed by the firm.
6.1 The Board's appetite for financial crime risk is set in the Risk Appetite Statement, approved annually alongside this Framework.
6.2 The portfolio is managed within that appetite. A position outside appetite is escalated to the Board through the reporting in §3.2, with a remediation path and a timeframe.
Does not itself set appetite (it points to the Risk Appetite Statement); it describes how Mittenda Limited manages the portfolio within appetite and escalates breaches. Escalation process owned by the firm, so evidence rather than a framework criterion.
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# Mittenda Limited · Financial Crime Framework (v
) · specimen excerpt > **Synthetic specimen.** Mittenda Limited is a fictional firm. This document is invented, > derived from scenarios seen in practice, and contains deliberate deficiencies for > demonstration. It is not a template and must not be adopted. **Document control:**
. | Version | Date | Change | |---|---|---| |
| February 2026 | Annual review, with the AML/CTF Policy cycle | | 1.1 | April 2025 | Crypto-asset services brought into scope on authorisation | | 1.0 | June 2024 | Initial issue, with the restructure of the policy estate over the Standards framework | **Contents** 1. **Purpose** 2. **The financial crime portfolio** 3. **Governance and accountability** 4. **The document framework** 5. **Risk assessment** 6. **Risk appetite** 7. Training, assurance and review Appendix A: Document register *Sections in bold are excerpted below.* ## 1. Purpose
## 2. The financial crime portfolio
## 3. Governance and accountability
## 4. The document framework
*[Section 7 and Appendix A omitted]*
Document text
Mittenda Limited · Financial Crime Framework (v1.2) · specimen excerpt
Synthetic specimen. Mittenda Limited is a fictional firm. This document is invented, derived from scenarios seen in practice, and contains deliberate deficiencies for demonstration. It is not a template and must not be adopted.
Document control: MTD-FRM-01 · owner: Head of Financial Crime (MLRO) · approved: the Board, 12 February 2026 · classification: Internal · supersedes: v1.1 · next review due: February 2027.
| Version | Date | Change |
|---|---|---|
| 1.2 | February 2026 | Annual review, with the AML/CTF Policy cycle |
| 1.1 | April 2025 | Crypto-asset services brought into scope on authorisation |
| 1.0 | June 2024 | Initial issue, with the restructure of the policy estate over the Standards framework |
Contents
- Purpose
- The financial crime portfolio
- Governance and accountability
- The document framework
- Risk assessment
- Risk appetite
- Training, assurance and review
Appendix A: Document register
Sections in bold are excerpted below.
1. Purpose
1.1 This Framework establishes how Mittenda organises the prevention of financial crime: the disciplines in scope, the accountability for each, the documents through which each is governed, and the assessment and appetite that direct them.
1.2 It is approved by the Board and reviewed at least annually. The policies and Standards made under it carry its requirements into each discipline; nothing in this Framework relieves any obligation under them.
2. The financial crime portfolio
2.1 The disciplines of the portfolio are: money laundering and terrorist financing; financial sanctions and restrictive measures; fraud; bribery and corruption; and the facilitation of tax evasion.
2.2 Each discipline is governed by the document named in §4.1 and owned by the role named there. Where a matter falls within more than one discipline, the Head of Financial Crime (MLRO) determines the lead discipline.
3. Governance and accountability
3.1 The Board owns this Framework and approves it annually, together with the Risk Appetite Statement.
3.2 The Head of Financial Crime (MLRO) is accountable for the portfolio and reports quarterly to the Board on the state of each discipline against the appetite set in the Risk Appetite Statement.
3.3 The Risk and Compliance Committee approves the Standards made under the AML/CTF Policy and oversees their operation and the measures reported under them.
4. The document framework
4.1 The governing document and owner for each discipline:
| Discipline | Governing document | Owner |
|---|---|---|
| Money laundering and terrorist financing | AML/CTF Policy | Head of Financial Crime (MLRO) |
| Financial sanctions and restrictive measures | AML/CTF Policy §11; Sanctions Screening Standard | Head of Financial Crime (MLRO) |
| Fraud | Fraud Policy | Head of Financial Crime (MLRO) |
| Bribery and corruption | Anti-Bribery and Corruption Policy | Head of Compliance |
| Facilitation of tax evasion | AML/CTF Policy, as a predicate offence to money laundering | Head of Financial Crime (MLRO) |
4.2 Each governing document is approved as §3 provides, is reviewed at least annually, and carries a document-control record in the MTD scheme. The Standards and Procedures beneath them are recorded in the document register at Appendix A.
5. Risk assessment
5.1 A business-wide financial crime risk assessment is performed at least annually, and on any material change to the business, covering each discipline of the portfolio across Mittenda's customers, products and services, delivery channels, geographies and transaction types.
5.2 The assessment is produced by the Head of Financial Crime (MLRO) and approved by the Board. Its conclusions calibrate the Standards and the risk-based procedures beneath them. For money laundering and terrorist financing it constitutes the assessment required by the AML/CTF Policy §3.
6. Risk appetite
6.1 The Board's appetite for financial crime risk is set in the Risk Appetite Statement, approved annually alongside this Framework.
6.2 The portfolio is managed within that appetite. A position outside appetite is escalated to the Board through the reporting in §3.2, with a remediation path and a timeframe.
[Section 7 and Appendix A omitted]
What it evidences
| Cited by | Suggestion | Version | When |
|---|---|---|---|
| Mittenda Limited | Coverage Not evidenced — Accompaniment incident and metrics monitoring sg-0379 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Coverage Not evidenced — Missing-information detection defect-metrics monitoring sg-0369 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Coverage Not evidenced — Verification defect metrics dashboard sg-0368 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Coverage Not evidenced — Beneficiary-information accompaniment defect metrics and incident monitoring sg-0362 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Coverage Not evidenced — Handling-defect MI monitoring sg-0329 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Add person Head of Compliance (person) — — sg-0015 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Add person the Board (group) — — sg-0013 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Coverage Not evidenced — Ongoing effectiveness testing of travel-rule policies sg-0009 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Add person Risk and Compliance Committee (group) — — sg-0006 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
| Mittenda Limited | Add person Head of Financial Crime (MLRO) — — sg-0004 | current — v1sha256 38b897b9fda2a96b7c2ea47edd9841eee0269a7852634e077db65c074e62f363 |
2026-10-04 20:13 |
Assistant findings
11 grounded in this documentWhat the assistant surfaced from this document — accept or reject them on the findings and coverage page.
| Finding | Value | Confidence | Status |
|---|---|---|---|
| Internal controls for implementing restrictive measures sg-0003 | Not evidenced | High | Accepted |
| Head of Financial Crime (MLRO) sg-0004 | Head of Financial Crime (MLRO) | High | Accepted |
| Risk and Compliance Committee sg-0006 | Risk and Compliance Committee (group) | High | Accepted |
| Ongoing effectiveness testing of travel-rule policies sg-0009 | Not evidenced | Medium | Accepted |
| the Board sg-0013 | the Board (group) | High | Accepted |
| Head of Compliance sg-0015 | Head of Compliance (person) | High | Accepted |
| Handling-defect MI monitoring sg-0329 | Not evidenced | Medium | Accepted |
| Beneficiary-information accompaniment defect metrics and incident monitoring sg-0362 | Not evidenced | Medium | Accepted |
| Verification defect metrics dashboard sg-0368 | Not evidenced | Medium | Accepted |
| Missing-information detection defect-metrics monitoring sg-0369 | Not evidenced | Medium | Accepted |
Audit timeline
Every event on this document (27)
| When (UTC) | Actor | What | Change |
|---|---|---|---|
| 2026-10-06 13:38:00 | Demo User | Document viewed | "MTD-FRM-01 · Financial Crime Framework (v1.2)" opened on the register detail. |
| 2026-10-06 13:38:00 | Demo User | Document content_accessed | Content read by a Restricted clearance (document Internal). |
| 2026-10-06 10:10:52 | Demo User | Document viewed | "MTD-FRM-01 · Financial Crime Framework (v1.2)" opened on the register detail. |
| 2026-10-06 10:10:52 | Demo User | Document content_accessed | Content read by a Restricted clearance (document Internal). |
| 2026-10-06 10:05:23 | Demo User | Document viewed | "MTD-FRM-01 · Financial Crime Framework (v1.2)" opened on the register detail. |
| 2026-10-06 10:05:23 | Demo User | Document content_accessed | Content read by a Restricted clearance (document Internal). |
| 2026-10-06 08:53:32 | Demo User | Document viewed | "MTD-FRM-01 · Financial Crime Framework (v1.2)" opened on the register detail. |
| 2026-10-06 08:53:32 | Demo User | Document content_accessed | Content read by a Restricted clearance (document Internal). |
| 2026-10-05 10:21:48 | Demo User | Document viewed | "MTD-FRM-01 · Financial Crime Framework (v1.2)" opened on the register detail. |
| 2026-10-05 10:21:48 | Demo User | Document content_accessed | Content read by a Restricted clearance (document Internal). |
| 2026-10-04 20:13:07 | Demo User | Document cited | Cited by an accepted suggestion. |
| 2026-10-04 20:13:07 | Demo User | Document cited | Cited by an accepted suggestion. |
| 2026-10-04 20:13:07 | Demo User | Document cited | Cited by an accepted suggestion. |
| 2026-10-04 20:13:07 | Demo User | Document cited | Cited by an accepted suggestion. |
| 2026-10-04 20:13:07 | Demo User | Document cited | Cited by an accepted suggestion. |
15 of 27 shown
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