Restrictions and orders
CDD Core restricts an account leg by leg, never all-or-nothing by accident. Each restriction is a case; the strictest active case decides; a command goes to the core system for every leg that changes, and the execution is confirmed back. Release needs documents and three signatures.
Who may do it: the system opens cases from rules · Maker (proposes release, records officer decisions) · Checker (endorses) · Approver (signs the release) · Compliance Officer, Head of Compliance and Internal Audit (read).
| Fund business — 4 legs | DA Dealer — 5 legs |
|---|---|
| Deposit · Withdraw · Buy · Sell | THB deposit · THB withdrawal · Trading · DA transfer-out · DA transfer-in access |
For a dealer, DA transfer-in access means the customer may not use assets received until the Travel Rule checks pass. Each leg is a separate command.
| Mode | Opened by | Effect |
|---|---|---|
| FULL LOCK | HR-03 match, where HR-03 is in the obligations | Every leg closed, within 24 hours of the case opening |
| FULL ASSET FREEZE | FREEZE-04 / FREEZE-05 match or a sanctioned country | Every leg closed; no transaction of any kind |
| EXIT-ONLY | Overdue review or EDD | Fund: deposit and buy closed; sell and withdraw to the verified same-name account open. Dealer: THB deposit, buying and DA transfer-out closed; selling and THB withdrawal to the registered bank account open |
A customer raised to High by institution policy keeps every leg open: policy outcomes never create a restriction.
Which case wins
Section titled “Which case wins”- The strictest active case decides. FULL LOCK and FULL ASSET FREEZE rank above EXIT-ONLY.
- A leg reopens only when no other case holds it. Completing a review closes the EXIT-ONLY case; if a restriction or freeze is still active, the account stays locked.
- Restricted and frozen accounts leave the review population until released.
Commands and execution
Section titled “Commands and execution”The Commands and execution screen puts two times on one line for every command: when it was sent and when the core system confirmed it was carried out. A command with no confirmation is shown as it is and is not counted as done. The HR-REPORT clock starts at the confirmation, never at the dispatch, and the 24-hour lock deadline is computed by the database.
- Fund business: commands go to the fund platform.
- DA Dealer: commands go to Trading Core, which confirms execution back to CDD Core.
Release
Section titled “Release”- Maker picks the account, enters the official case reference, attaches the police, court or AMLO document (PDF or PNG) — for a restriction a state authority ordered, the authority’s own release order, with its reference recorded — writes the justification and presses Propose to checker.
- Checker checks the documents and endorses, or returns.
- Approver presses Sign release. The system sends the release for every leg no other case holds, and follows it on the commands screen.
DA Dealer edition — limits
Section titled “DA Dealer edition — limits”- Withdrawal limits follow the class. The Head of Compliance sets the daily schedules for classes S and M from the association guideline; class L amounts are set per customer on its class record.
- Each change issues a new limit set with its own number, pushed to Trading Core; the same amounts again issue nothing.
- Mule tiers received from the agencies open their cases and timers in the same way as a list match.
What the system does or refuses
Section titled “What the system does or refuses”- No override button for a state-authority restriction. It is lifted only when the authority’s release order is recorded, through the route above.
- A command is stored before it is sent, and each leg carries its own command reference.