What is AML/CFT (anti-money laundering) and who must comply
Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT; PLD/FT in Portuguese) is the set of policies, procedures and controls institutions adopt to prevent the financial system from being used for illicit purposes. It is the “umbrella” that brings together customer identification, screening and monitoring.
What money laundering is and what Brazil's Law 9,613/1998 says
Money laundering is the process of giving a lawful appearance to funds of criminal origin, integrating them into the formal economy. In Brazil, Law 9,613/1998 defines the crime, sets out the prevention obligations and created the Financial Activities Control Council (COAF), responsible for receiving and analyzing reports of suspicious operations.
Who must comply with AML
The obligation falls on financial institutions, payment service providers, virtual asset service providers (crypto) and other regulated sectors, which must maintain AML programs proportionate to their size and risk, under the supervision of the authorities. In Brazil, the Central Bank (BACEN) supervises the financial system, and COAF acts as the financial intelligence unit (FIU), receiving reports of suspicious operations.
The pillars of AML in practice
- Know Your Customer (KYC): identify and verify the customer's identity, understand the purpose of the relationship and map the ownership structure and beneficial owners (CDD).
- Screening against watchlists: cross-check customers and other parties against sanctions, PEP and restriction lists.
- Ongoing monitoring: follow the relationship over time to identify atypical operations and changes in risk.
Where screening fits
Screening is not a synonym for AML; it is one of its controls. While AML/CFT covers the whole governance (policies, reporting, training), screening is the operational tool that detects exposure to sanctions, restrictions and PEPs. It is also where the identification of PEPs and the resulting enhanced due diligence come in.
How Orvyan supports
Orvyan is the infrastructure for screening within AML: it cross-checks the queried data (name or tax ID) against the lists and returns the risk classification: HIGH, MEDIUM, LOW or CLEAR. It is decision support: it recommends and flags, but the decision and the responsibility for the AML program are always the institution's.
Sources
- Brazil's Law 9,613/1998 (money laundering): planalto.gov.br
- Central Bank Circular 3,978/2020 (AML/CFT): bcb.gov.br
- COAF, Financial Activities Control Council: gov.br/coaf
- FATF, Recommendations: fatf-gafi.org
Frequently asked questions
Where does Orvyan fit in an AML program?
In the screening pillar: Orvyan cross-checks people and companies (by name or tax ID) against sanctions, PEP and restriction lists, in a single query.
Does a screening alert confirm money-laundering risk?
No. The alert is the first step: it flags a similarity to a list record. You need to review the match, the source, the type of list and the context of the relationship to decide whether the alert requires action or should be treated as a false positive.
Does using Orvyan exempt my institution from reporting operations to the financial intelligence unit?
No. Orvyan provides the list-screening infrastructure. AML governance and the legal duty to report suspicious operations to the financial intelligence unit (in Brazil, COAF) remain direct obligations of the institution.