AML Compliance Tracking

BlockManOS includes a built-in AML (Anti-Money Laundering) compliance module designed to help property management agents meet obligations under Irish legislation — specifically the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010–2021.

The module tracks Customer Due Diligence (CDD) checks for OMC directors, company secretaries, and landlord/investor owners, covering identity verification, address proof, and sanctions screening.

Who Requires AML Checks

The following subject types are tracked within the platform:

Subject Type	Description
`director`	OMC board director
`secretary`	Secretary linked to an OMC
`company_secretary`	Formally designated company secretary
`owner_landlord`	Owner classified as a landlord or investor

Accessing the AML Dashboard

Navigate to Dashboard → Compliance → AML Compliance (/dashboard/aml).

The dashboard has two tabs:

AML Records — all existing AML checks with search, status filter, and subject type filter.
Persons Requiring AML — a cross-reference of active directors and landlord owners against existing AML records, highlighting anyone who does not yet have an AML check in progress.

Summary Cards

Eight at-a-glance metrics are displayed at the top of the dashboard:

Card	Description
Total	Total AML records across the organisation
Not Started	Records created but no action taken
In Progress	Active checks underway
Passed	Completed checks with a passing result
Failed	Checks that resulted in a failure
Expired	Checks that have passed their review date
Sanctions	Records with a potential or confirmed sanctions match
High Risk	Records classified as high risk

Failed, Expired, Sanctions, and High Risk cards are visually highlighted when their count is above zero.

AML Record Status Workflow

Each AML record progresses through the following statuses:

not_started → in_progress → pending_documents → under_review → passed
                                                             → failed
                                                             → expired

When updateStatus is called to set a record as passed or failed, the system automatically records the completion date. Review dates are set to prompt periodic re-checking.

Risk Levels

Each record carries a risk classification: low, medium, or high.

Risk level is automatically escalated when a sanctions check returns a potential_match or confirmed_match result.

CDD Checklist

Each AML record tracks three core CDD components:

1. Proof of Identity

Accepted document types:

Passport
Driving licence
National ID card

Recorded fields: document type, document number, expiry date, verification status.

2. Proof of Address

Accepted document types:

Utility bill
Bank statement
Revenue letter

Recorded fields: document type, document date, verification status.

3. Sanctions Screening

Three registers must be checked independently:

Register	Description
EU	European Union consolidated sanctions list
UK	UK Office of Financial Sanctions Implementation (OFSI)
US-OFAC	US Treasury Office of Foreign Assets Control

Each check records a result:

clear — No match found
potential_match — Possible match requiring review
confirmed_match — Match confirmed; triggers high-risk escalation

Match details can be recorded as free text.

Other Directorships

Each AML record can store a list of other directorships held by the subject. Each entry records:

Company name
CRO (Companies Registration Office) number
Role

This is stored as a structured JSONB array and can be managed from the Other Directorships tab in the record detail panel.

Audit Trail

Every action taken on an AML record — verification steps, status changes, sanctions checks — is written to an immutable aml_activity_log. This log is visible in the Activity History tab of the record detail panel and provides a full timestamped audit trail suitable for regulatory review.

Starting an AML Check

From scratch

Go to /dashboard/aml.
Click New AML Check.
Select the subject type and complete personal details.
Link the record to an existing director or owner if applicable.

From the Persons Requiring AML tab

Switch to the Persons Requiring AML tab.
Locate the director or landlord owner without an existing AML record.
Click Start AML — the creation form opens pre-filled with their name, email, and role/ownership type.

Identifying Compliance Gaps

The aml.listRequiringAml endpoint cross-references all active directors and landlord/investor owners against the aml_records table. It returns subjects who either have no AML record or whose existing record has a status of failed or expired. This powers the Persons Requiring AML tab.

API Reference Summary

All AML endpoints are available under the aml tRPC router and are scoped to the authenticated organisation.

Procedure	Type	Access	Description
`aml.list`	Query	Org	List records with optional filters
`aml.getById`	Query	Org	Fetch full record with activity log
`aml.summary`	Query	Org	Dashboard aggregate stats
`aml.listRequiringAml`	Query	Org	Identify directors/owners needing AML
`aml.create`	Mutation	Org	Create a new AML record
`aml.update`	Mutation	Org	Update personal details / directorships
`aml.verifyIdDocument`	Mutation	Org	Record ID document verification
`aml.verifyAddressDocument`	Mutation	Org	Record address proof verification
`aml.recordSanctionsCheck`	Mutation	Org	Record a sanctions register check
`aml.updateStatus`	Mutation	Admin	Update AML check status
`aml.delete`	Mutation	Admin	Delete record and activity log

Legislative Context

This module is designed to support compliance with:

Criminal Justice (Money Laundering and Terrorist Financing) Act 2010
Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021

Property management agents acting as designated persons under Irish AML legislation are required to apply CDD measures to certain clients and beneficial owners. BlockManOS does not provide legal advice — agents should consult their compliance officer or legal advisor regarding their specific obligations.