Governance & Legal

AML & KYC Policy

OCRE implements a rigorous Anti-Money Laundering program and multi-tiered Know Your Customer verification to ensure all participants meet institutional compliance standards.

Anti-Money Laundering Program

OCRE's AML program is designed to detect, prevent, and report money laundering activities across all platform operations. Transaction monitoring algorithms analyze clearing patterns, physical warrant transfers, and payment flows to identify suspicious behavior. All staff receive mandatory AML training annually, and the program undergoes quarterly independent audits.

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Identity Verification
Government-issued ID validation, biometric matching, and document authenticity checks for every individual and authorized signatory.
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Entity Verification
Company registration confirmation, Legal Entity Identifier (LEI) validation, and corporate structure mapping for all institutional accounts.
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Source of Funds
Documented origin of capital for all clearing deposits. Enhanced scrutiny on fund flows from high-risk jurisdictions or unusual sources.
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Beneficial Ownership
Full disclosure of Ultimate Beneficial Owners (UBOs) at the 10% threshold for institutional accounts. PEP screening on all disclosed individuals.

KYC Verification Tiers

  • Tier 1 — Standard: Government-issued ID verification, company registration, LEI validation, authorized signatory confirmation
  • Tier 2 — Enhanced: Source-of-funds documentation, beneficial ownership chain (10%+ threshold), PEP screening, and adverse media checks
  • Tier 3 — Deep Diligence: On-site verification, independent background investigations, reference checks from existing financial institutions
  • Ongoing — Continuous: Transaction pattern monitoring, periodic document refresh (annual), counterparty re-screening (daily)

Suspicious Activity Reporting

OCRE files Suspicious Activity Reports (SARs) with FinCEN for any transaction or behavior that indicates potential money laundering, terrorist financing, or sanctions evasion. The compliance team has direct escalation authority and operates independently of commercial functions. Currency Transaction Reports (CTRs) are filed automatically for applicable thresholds.

KYC Documentation

Request copies of OCRE's KYC procedures or AML program documentation for your compliance review.

Request Documents