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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).

Restrictions and commandsA restriction case opens; the effective state is the strictest active case; the system sends one command per leg; the core system executes and confirms back; both times are kept and reporting clocks start at confirmation. A release needs documents and three signatures, and a leg reopens only when no other case holds it.EXECUTION CONFIRMEDCase opensoverdue review · list matchauthority letter · officerEffective statestrictest active case winsFULL LOCK > EXIT-ONLYOne command per legfund business: 4DA Dealer: 5Core systemfund platformTrading CoreTwo timestampssent · confirmedclocks start at confirmationReleasepolice, court or AMLO document · Maker → Checker → Approvera leg reopens only when no other case holds itLEGENDStepSystem decidesCore systemRecordReturn path
One command per leg, two timestamps per command. Reporting clocks start when execution is confirmed, never when the command is sent.
Fund business — 4 legsDA Dealer — 5 legs
Deposit · Withdraw · Buy · SellTHB 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.

ModeOpened byEffect
FULL LOCKHR-03 match, where HR-03 is in the obligationsEvery leg closed, within 24 hours of the case opening
FULL ASSET FREEZEFREEZE-04 / FREEZE-05 match or a sanctioned countryEvery leg closed; no transaction of any kind
EXIT-ONLYOverdue review or EDDFund: 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.

  • 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.

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.
  1. 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.
  2. Checker checks the documents and endorses, or returns.
  3. Approver presses Sign release. The system sends the release for every leg no other case holds, and follows it on the commands screen.
  • 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.
  • 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.