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Guide

ANTI-MONEY
LAUNDERING.

Reference

Trade is one of the oldest routes for moving illicit value, and trade-based laundering does not look like crime — it looks like an ordinary invoice for the wrong amount. The obligations fall on the parties to the transaction, including ones who did nothing wrong.

What trade-based laundering looks like

Value is moved by misrepresenting a trade, not by hiding a payment. The transaction is real; the numbers are not.

  • Over- or under-invoicing to shift value across a border
  • Multiple invoices for a single shipment
  • Goods described as something more or less valuable than they are
  • Payment from a third party with no role in the trade

Know your counterparty

Identifying who you are actually trading with — including who ultimately owns them — is the baseline obligation almost everywhere. A company you cannot see the owner of is the specific risk the rules exist for.

Sanctions are strict liability

Dealing with a sanctioned party is an offence whether or not you knew. Screening counterparties against the lists that apply to you is not optional, and "we did not know" is not a defence anywhere it matters.

What the protocol does

GRAJ verifies operator identity at the level an action requires, records who did what in an append-only log, and refuses to let anyone approve their own verification. Sanctions screening and the legal determinations around it belong with counsel, not a platform.

Where to go next
/kyc/persona/compliance
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