Fintech Lab
Lesson 34Risk and limitsIntermediate
AML transaction monitoring and held states
Funds arrive but stay in escrow until compliance clears the transaction.

A user attempts a ₦1,000,000 deposit. Your AML rules trigger, the source jurisdiction is on a high-risk list, the amount is unusual for this user's history, or the pattern resembles structuring. The cash physically arrives in your FBO account at the sponsor bank (you can't stop the wire), but you do NOT credit the user's wallet. The funds sit in an 'AML Held' liability while your compliance team investigates. Days or weeks later, compliance either CLEARS (release to user) or ESCALATES (file SAR with regulator, funds stay held indefinitely pending guidance). The ledger trail is the regulatory evidence, exactly what the regulator's first question will demand.

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