MTD-POL-03 · Risk Appetite Statement (v2.0)

Identity, integrity & provenance

Document id

mtd-pol-03

sha256 (the integrity anchor citations pin to)

21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a

Covers the extracted text, 3286 characters of it.

Added by

Demo User

Added at

2026-10-04 18:51 UTC

Source

register_document

Retain until

2032-10-04

Document control — provenance carried to the assessment stages as evidence metadata

Reference

MTD-POL-03

Version

2.0

Owner

Head of Risk

Approved

the Board, 12 February 2026

Classification

Internal

Supersedes

v1.1

Next review due

February 2027

Allocated to assessments

Where this document's content was filed at triage — 7 sections. A section can be allocated to more than one assessment. Change it with Triage and allocate, in the actions at the top of this page.

1.1 Purpose and scope of the Statement

1.1 This Statement sets the Board's appetite for the principal risks Mittenda assumes in operating its payment services and crypto-asset services. It is approved annually and applies to all business.

Framework (org-wide)

Board-set org-wide risk appetite: the Board owns this Statement and it applies to all business; no single assessment unit owns it, every assessment inherits it.

1.2 Appetite grades

1.2 Appetite is expressed in three grades. No appetite: Mittenda accepts no exposure, and any occurrence is escalated to the Board. Low appetite: exposure is accepted only within the stated tolerances. Moderate appetite: exposure is accepted and managed within the limits of the relevant risk framework.

Framework (org-wide)

Board-set definition of the appetite grades the Statement uses; an org-wide criterion owned by the Board. These are appetite grades, not a scale on which risk is rated, so the section is not marked ratingScale.

1.3 Monitoring measures and breach escalation

1.3 Each statement carries the measures by which it is monitored and the route by which a breach of tolerance escalates, reported under §7.

Framework (org-wide)

Part of the Board's appetite framework: states how each appetite statement is monitored and how breaches of tolerance escalate. Org-wide criterion, not owned by one unit.

5.1 No appetite for breach of non-risk-based financial crime obligations

5.1 Mittenda has no appetite for breach of those of its financial crime obligations that admit no risk-based application: the obligations that must be met for every customer and every transaction, without exception.

Framework (org-wide)

Board-set appetite statement for financial crime risk (no appetite grade); an org-wide criterion every assessment inherits.

5.2 Low appetite for residual financial crime risk

5.2 Mittenda accepts that the inherent risk of money laundering, terrorist financing and the other portfolio disciplines cannot be eliminated in a firm that serves customers and executes transfers. It holds a low appetite for residual financial crime risk after the operation of its control framework, within the tolerances of §5.3.

Framework (org-wide)

Board-set appetite statement for residual financial crime risk (low appetite grade); an org-wide criterion every assessment inherits.

5.3 Financial crime tolerances and measures

5.3 Tolerances and measures:

Measure Tolerance Escalation

Sanctions screening alerts unresolved beyond two working days None outstanding Head of Financial Crime (MLRO), daily; Risk and Compliance Committee, monthly

Confirmed sanctions matches released Zero The Board, without delay

Transaction monitoring alerts unresolved beyond ten working days Under 5% of open alerts Risk and Compliance Committee, monthly

Customer due diligence periodic reviews past due Under 2% of the customer book, cleared within 60 days Risk and Compliance Committee, monthly

Financial crime training completion 98% within one month of due date Risk and Compliance Committee, quarterly

Framework (org-wide)

Board-set risk tolerances and limits with their escalation routes; org-wide criteria the Board owns and every assessment inherits.

5.4 Reporting of financial crime measures

5.4 The measures in §5.3 are reported to the Risk and Compliance Committee monthly and to the Board quarterly, through the reporting of the Financial Crime Framework §3.2.

Framework (org-wide) Medium confidence

Part of the Board's appetite framework: sets the reporting cadence of the tolerance measures to the Committee and the Board. Org-wide criterion, not owned by one unit.

Not allocated

Text no triage section covers — 6 passages. Often this is the title, document-control metadata or sign-off; if any of it belongs to an assessment, file it with Triage and allocate, in the actions at the top of this page.

# Mittenda Limited · Risk Appetite Statement (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 approval; financial crime statements restructured against the Financial Crime Framework | | 1.1 | April 2025 | Crypto-asset services brought into scope on authorisation | | 1.0 | June 2024 | Initial issue | **Contents** 1. **Purpose and approach** 2. Prudential and liquidity risk 3. Operational and technology risk 4. Safeguarding 5. **Financial crime risk** 6. Conduct and customer outcomes 7. Monitoring and escalation *Sections in bold are excerpted below.* ## 1. Purpose and approach

*[Sections 2 to 4 omitted]* ## 5. Financial crime risk

*[Sections 6 onward omitted]*

Document text

3286 chars

Mittenda Limited · Risk Appetite Statement (v2.0) · 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-POL-03 · owner: Head of Risk · approved: the Board, 12 February 2026 · classification: Internal · supersedes: v1.1 · next review due: February 2027.

Version	Date	Change
2.0	February 2026	Annual approval; financial crime statements restructured against the Financial Crime Framework
1.1	April 2025	Crypto-asset services brought into scope on authorisation
1.0	June 2024	Initial issue

Contents

Purpose and approach
Prudential and liquidity risk
Operational and technology risk
Safeguarding
Financial crime risk
Conduct and customer outcomes
Monitoring and escalation

Sections in bold are excerpted below.

1. Purpose and approach

1.1 This Statement sets the Board's appetite for the principal risks Mittenda assumes in operating its payment services and crypto-asset services. It is approved annually and applies to all business.

1.2 Appetite is expressed in three grades. No appetite: Mittenda accepts no exposure, and any occurrence is escalated to the Board. Low appetite: exposure is accepted only within the stated tolerances. Moderate appetite: exposure is accepted and managed within the limits of the relevant risk framework.

1.3 Each statement carries the measures by which it is monitored and the route by which a breach of tolerance escalates, reported under §7.

[Sections 2 to 4 omitted]

5. Financial crime risk

5.1 Mittenda has no appetite for breach of those of its financial crime obligations that admit no risk-based application: the obligations that must be met for every customer and every transaction, without exception.

5.2 Mittenda accepts that the inherent risk of money laundering, terrorist financing and the other portfolio disciplines cannot be eliminated in a firm that serves customers and executes transfers. It holds a low appetite for residual financial crime risk after the operation of its control framework, within the tolerances of §5.3.

5.3 Tolerances and measures:

Measure	Tolerance	Escalation
Sanctions screening alerts unresolved beyond two working days	None outstanding	Head of Financial Crime (MLRO), daily; Risk and Compliance Committee, monthly
Confirmed sanctions matches released	Zero	The Board, without delay
Transaction monitoring alerts unresolved beyond ten working days	Under 5% of open alerts	Risk and Compliance Committee, monthly
Customer due diligence periodic reviews past due	Under 2% of the customer book, cleared within 60 days	Risk and Compliance Committee, monthly
Financial crime training completion	98% within one month of due date	Risk and Compliance Committee, quarterly

5.4 The measures in §5.3 are reported to the Risk and Compliance Committee monthly and to the Board quarterly, through the reporting of the Financial Crime Framework §3.2.

[Sections 6 onward omitted]

What it evidences

Risks (1):Restrictive-measures policies, procedures and controls not in place

Controls (17):Restrictive-measures management dashboard and incident reporting Service-level latency for rejection flagging Beneficiary-name accompaniment policy and staff training Handling-defect MI monitoring Originator-name accompaniment policy and training Handling policy and staff training Admissibility-detection defect metrics dashboard Admissibility-detection policy and staff training Staff training and competency on admissibility validation rules Beneficiary-information accompaniment policy and staff training Beneficiary-information accompaniment defect metrics and incident monitoring Verification defect metrics dashboard

12 of 17 shown

Obligations (2):Percentage of a counterparty's transfers with missing information as a criterion Percentage of unanswered follow-up requests as a criterion

Cited by (24):

Cited by	Suggestion	Version	When
Mittenda Limited	Coverage Not evidenced — Accompaniment incident and metrics monitoring sg-0379	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Partial — Originator-information accompaniment policy and training sg-0376	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Verification policy and staff training sg-0374	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Partial — Missing-information detection policy and staff training sg-0375	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Missing-information detection defect-metrics monitoring sg-0369	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Verification defect metrics dashboard sg-0368	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Beneficiary-information accompaniment defect metrics and incident monitoring sg-0362	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Partial — Beneficiary-information accompaniment policy and staff training sg-0356	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Staff training and competency on admissibility validation rules sg-0355	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13
Mittenda Limited	Coverage Partial — Admissibility-detection policy and staff training sg-0354	current — v1`sha256 21690461b61097b59823a5cfa8e11f06be05887cb174407656b72e7a866c603a`	2026-10-04 20:13

10 of 24 shown

Assistant findings

31 grounded in this document

What the assistant surfaced from this document — accept or reject them on the findings and coverage page.

Finding	Value	Confidence	Status
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
All categories sg-0010	Appetite All categories: Low (approved by the Board)	Medium	Accepted
the Board sg-0013	the Board (group)	High	Accepted
CC-SANCTIONS sg-0014	Appetite CC-SANCTIONS: Low (approved by the Board)	Medium	Accepted
CC-SANCTIONS sg-0024	Tolerance CC-SANCTIONS: Low	High	Accepted
CC-SANCTIONS sg-0025	Tolerance CC-SANCTIONS: Low	High	Accepted
All categories sg-0026	Tolerance All categories: Low	High	Accepted
All categories sg-0027	Tolerance All categories: Low	High	Accepted
All categories sg-0028	Tolerance All categories: Low	High	Accepted

10 of 31 shown

Audit timeline

Every event on this document (41)

When (UTC)	Actor	What	Change
2026-10-06 13:37:59	Demo User	Document viewed	"MTD-POL-03 · Risk Appetite Statement (v2.0)" opened on the register detail.
2026-10-06 13:37:58	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 10:10:51	Demo User	Document viewed	"MTD-POL-03 · Risk Appetite Statement (v2.0)" opened on the register detail.
2026-10-06 10:10:51	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 10:05:22	Demo User	Document viewed	"MTD-POL-03 · Risk Appetite Statement (v2.0)" opened on the register detail.
2026-10-06 10:05:22	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 08:53:31	Demo User	Document viewed	"MTD-POL-03 · Risk Appetite Statement (v2.0)" opened on the register detail.
2026-10-06 08:53:30	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-05 10:21:40	Demo User	Document viewed	"MTD-POL-03 · Risk Appetite Statement (v2.0)" opened on the register detail.
2026-10-05 10:21:40	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-04 22:05:04	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.
15 of 41 shown