What is AML?

A plain-language introduction for everyone at Artha — no compliance background needed. It covers what money laundering is, what we have to do about it as a Canadian money services business, how our systems catch it in real time, and why we chose Checkmarble.

In one sentence: Anti-Money Laundering (AML) is the set of laws, checks and systems that stop criminals from using businesses like ours to make dirty money look clean.

1. AML in one minute

Money laundering is, in FINTRAC's words, "the process used to disguise the source of money or assets derived from criminal activity." A drug dealer, a fraudster or a ransomware gang ends up with money they cannot openly spend. Laundering is how they disguise where it came from, so it looks like it was earned honestly.

Terrorist financing is the reverse problem. The money may be perfectly clean — a salary, a donation — but it is being sent to fund terrorism. FINTRAC describes it as using funds or property "to encourage, plan, assist or engage in acts of terrorism, where the primary motivation is not financial gain."

AML (often written AML/CTF — anti-money laundering and counter-terrorist financing) covers both.

Why it matters: the United Nations Office on Drugs and Crime estimates that 2–5% of global GDP — roughly US$800 billion to US$2 trillion — is laundered every year. Crypto is attractive to criminals because it moves fast, crosses borders instantly, and can be split across many wallets. That is why platforms like ours are on the front line.

2. How laundering works — the three stages

FINTRAC describes laundering in three stages. Real schemes blur them, but the model makes the pattern easy to spot.

flowchart LR
  A["Criminal cash<br/>or stolen crypto"] --> P["1 · Placement<br/>get it into the system"]
  P --> L["2 · Layering<br/>hide the trail"]
  L --> I["3 · Integration<br/>spend it as 'clean'"]
  I --> C["Looks legitimate:<br/>house, car, business"]

Our job is to catch it at stage 1 or 2 — before the money leaves our platform looking clean.

3. A real-time example — one suspicious customer, step by step

This is an illustrative scenario (not a real customer) that walks one person through our actual compliance stack, showing what happens in the seconds after each action.

Meet "Sam". Sam opens an account, passes identity checks, and over five days deposits USDT that adds up to about CAD 33,000 — then asks to withdraw everything to a brand-new private wallet.

What happens every time Sam deposits — in about a second

sequenceDiagram
  participant S as Sam
  participant P as Artha platform
  participant O as Compliance orchestrator
  participant A as AMLBot
  participant M as Checkmarble (Marble)
  participant Q as Alert & case queue
  S->>P: Deposit 9,500 CAD of USDT
  P->>O: Send the transaction event
  O->>A: Where did these coins come from?
  A-->>O: Risk score + exposure (e.g. mixer)
  O->>M: Run the rules (amount, history, risk)
  M-->>O: Decision: Approve / Review / Decline
  O-->>P: Release, hold, or reject the deposit
  O->>Q: If Review or worse → alert for an analyst
  Note over O,M: The 24-hour total and reporting duties are checked every time, whatever the decision

Sam's week, and what each control does

Two things beginners often miss:

• Reporting is not accusing. An STR says "we have reasonable grounds to suspect". FINTRAC investigates; we don't.
• Reports are independent. Filing the STR does not replace the LVCTR from Day 1. Both are required.

Where we are today: Sumsub, AMLBot and the Checkmarble rule engine are live. The alert queue, the link into case management, sanctions screening and FINTRAC reporting are being built — see the Requirements tab, section 4.

4. Real cases — what happens when AML fails

These are real enforcement actions, most of them in Canada. Every one comes down to the basics in this page.

The lesson: regulators don't only punish laundering that happened — they punish missing controls. Unfiled reports, unmonitored transactions and missing risk assessments are violations on their own.

5. What our Canadian registration means

We are registered with FINTRAC (the Financial Transactions and Reports Analysis Centre of Canada) as a Money Services Business (MSB) that deals in virtual currency. FINTRAC is Canada's financial intelligence unit and AML supervisor. The law behind it is the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

"Licence" or "registration"? We often say "MSB licence", but FINTRAC's own wording is registration: "FINTRAC does not issue licenses or certificates of registration." Registration must be renewed every 2 years. Use "FINTRAC MSB registration" in anything formal.

What the registration requires of us

6. Future licences — same ideas, different rulebooks

If we expand beyond Canada, the building blocks stay the same — identify customers, screen names and wallets, monitor transactions, report suspicion, keep records, apply the Travel Rule. What changes is the regulator, the report names, the thresholds and the deadlines.

International standards come from the FATF (Financial Action Task Force), the Paris-based "global money laundering and terrorist financing watchdog" whose standards more than 200 jurisdictions have committed to. That is why every regime looks familiar.

What this means for how we build: keep thresholds, report types and deadlines as configuration per jurisdiction, not hard-coded logic. A new licence should mean new rules and report formats — not a new platform. Checkmarble scenarios and the compliance orchestrator are designed for exactly that.

7. What is Checkmarble?

Checkmarble is a Paris-based company (Marble SAS), founded by people who previously ran fraud, AML and compliance at the French fintech Shine. Its product, Marble, describes itself as "the real time decision engine for fraud and AML" — a platform for transaction monitoring, AML screening and case investigation, built for "banks, fintechs, crypto exchange and any company moving money."

How Marble works

flowchart LR
  D["Our data<br/>customers, accounts,<br/>transactions"] -->|Ingestion API| M["Marble"]
  T["A new transaction"] -->|Decision API| M
  M --> R["Scenarios<br/>rules that add or<br/>subtract risk score"]
  R --> X{"Score vs<br/>thresholds"}
  X --> A1["Approve"]
  X --> A2["Review"]
  X --> A3["Block and Review"]
  X --> A4["Decline"]
  A2 --> C["Case manager<br/>& audit trail"]
  A3 --> C

• Data in. We send Marble our customers, accounts and transactions through its Ingestion API, so rules can look at history — not just one payment.
• Scenarios. Compliance builds rules without writing code. Each rule adds or subtracts risk score, for example "3+ deposits between CAD 8,000 and 9,999 in 7 days" or "coins came through a mixer".
• Decisions in real time. For each transaction our platform calls the Decision API and gets an outcome back. Marble's outcomes are Approve, Review, Block and Review, Decline. Our Requirements document names three actions — APPROVE, REVIEW, BLOCK — and maps them onto these.
• Batch runs. Scenarios can also run on a schedule, to catch slow patterns such as structuring over a week.
• Case manager and audit trail. Marble includes a case manager and "searchable and unalterable" audit logs. Whether we use it or connect our own case management is open item O-05 in the Requirements.
• Screening (add-on). Marble Screening checks names against sanctions lists, politically exposed persons and adverse media, using OpenSanctions or LexisNexis data.

8. Why Checkmarble?

Honest caveats

• "Open source" means source-available. The core is free under the Elastic License 2.0. That licence allows self-hosting, but it is not an OSI-approved open-source licence, and it forbids offering Marble as a service to third parties.
• Screening is a paid feature. Marble Screening needs a licence key from Checkmarble, and the sanctions data (OpenSanctions) needs its own commercial licence. Self-hosted screening also needs extra infrastructure (Elasticsearch and OpenSanctions indexing).
• Not everything is available self-hosted. Checkmarble's documentation says its AI case-review features are currently for their SaaS customers.
• Canada is our job, not the vendor's. Marble doesn't come pre-configured for FINTRAC. Canadian thresholds, lists and reports are ours to configure and prove. A vendor performs a function; it never takes on our obligation.

9. Quick glossary

For the full detail, see the Requirements tab.

Sources

Checked 18 September 2026.

• FINTRAC — money laundering, terrorist financing and the three stages: https://fintrac-canafe.canada.ca/fintrac-canafe/1-eng
• FINTRAC — MSB definition: https://fintrac-canafe.canada.ca/msb-esm/msb-eng
• FINTRAC — registration is not a licence: https://fintrac-canafe.canada.ca/msb-esm/reg-eng
• FINTRAC — compliance program requirements: https://fintrac-canafe.canada.ca/guidance-directives/compliance-conformite/guide4/4-eng
• FINTRAC — record keeping for MSBs: https://fintrac-canafe.canada.ca/guidance-directives/recordkeeping-document/record/msb-eng
• FINTRAC — LVCTR: https://fintrac-canafe.canada.ca/guidance-directives/transaction-operation/lvctr/lvctr-eng
• FINTRAC — Travel Rule: https://fintrac-canafe.canada.ca/guidance-directives/transaction-operation/travel-acheminement/1-eng
• FINTRAC — 24-hour rule: https://fintrac-canafe.canada.ca/guidance-directives/transaction-operation/24hour/1-eng
• FINTRAC — Xeltox Enterprises (Cryptomus) penalty: https://fintrac-canafe.canada.ca/new-neuf/nr/2025-10-22-eng
• FINTRAC — TD Bank penalty: https://fintrac-canafe.canada.ca/new-neuf/nr/2024-05-02-eng
• FINTRAC — Binance penalty: https://fintrac-canafe.canada.ca/new-neuf/nr/2024-05-09-eng
• US Department of Justice — TD Bank guilty plea: https://www.justice.gov/archives/opa/pr/td-bank-pleads-guilty-bank-secrecy-act-and-money-laundering-conspiracy-violations-18b
• US Department of Justice — Binance guilty plea: https://www.justice.gov/archives/opa/pr/binance-and-ceo-plead-guilty-federal-charges-4b-resolution
• UNODC — global money laundering estimate: https://www.unodc.org/unodc/en/money-laundering/overview.html
• FATF — who we are: https://www.fatf-gafi.org/en/the-fatf/who-we-are.html
• FinCEN — MSB registration: https://www.fincen.gov/resources/money-services-business-msb-registration
• FinCEN — funds Travel Rule: https://www.fincen.gov/resources/statutes-regulations/guidance/funds-travel-regulations-questions-answers
• ESMA — end of MiCA transitional periods: https://www.esma.europa.eu/sites/default/files/2026-04/ESMA75-113276571-1679_Statement_on_the_end_of_transitional_periods_under_MiCA.pdf
• European Parliament — EU crypto transfer tracing rules: https://www.europarl.europa.eu/news/en/press-room/20230414IPR80133/crypto-assets-green-light-to-new-rules-for-tracing-transfers-in-the-eu
• FCA — cryptoasset registration: https://www.fca.org.uk/firms/cryptoassets-aml-ctf-regime/cryptoasset-registration-information-applicants
• FCA — UK Travel Rule expectations: https://www.fca.org.uk/news/statements/fca-sets-out-expectations-uk-cryptoasset-businesses-complying-travel-rule
• Checkmarble — Marble on GitHub: https://github.com/checkmarble/marble
• Checkmarble — what is Marble: https://docs.checkmarble.com/docs/what-is-marble
• Checkmarble — decision outcomes: https://docs.checkmarble.com/docs/decision-1
• Checkmarble — scenario versioning: https://docs.checkmarble.com/docs/versioning
• Checkmarble — Marble Screening: https://docs.checkmarble.com/docs/introduction-9
• Checkmarble — about the company: https://www.checkmarble.com/about