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gateAML — Not one country. Every jurisdiction.
// Architecture

Eight sub gates, executed in parallel.

Every row is a hard boolean check, not probabilistic scoring. A critical failure leads to block, a high severity failure to warn, everything else to pass.

ReferenceChecksSeverity
gateAMLRAMLR 2024/1624 and AMLD4/5/6, CDD, UBO chain, FATF black and grey list, PEP detection, cash thresholdscritical
gateOFACLive API screening against OFAC SDN and the EU consolidated list, jurisdiction embargoes, fuzzy name matchingcritical
gateFATF40Ten of the 40 FATF recommendations, CDD, wire transfer travel rule, PEP procedures, UBO registerhigh
gateWireTransferEU Wire Transfer Regulation 2015/847, complete originator and beneficiary informationcritical
gatePATRIOTUS PATRIOT Act Section 314, FinCEN information request, MSB registrationcritical
gateWolfsbergWolfsberg Principles, KYC utility, adverse media screening for correspondent banksmedium
gatePTAccountGwG CH Art. 15 lit. f, payable-through account, end customer identification, nGwV-FINMA 2027high
NorthDataLive corporate registry DE/AT/CH, dissolution status, commercial register entry, non-blocking on API failurehigh
HMAC-signed GateLog record
Every run writes an HMAC-signed GateLog record with identity binding (caller_did, caller_role) and a ten-year retention period. Deterministic: identical input produces identical output, no LLM, no external API.
// Clarification

What gateAML is not.

  • Not hardcoded sanctions lists. gateAML queries OFAC and the EU consolidated list live, with a four-hour cache as a compromise between freshness and performance.
  • Not a silent failure on API outage. If a live source fails, the gate honestly returns warn with a note to screen manually, instead of silently waving through or blocking.

For institutions that want a cross-sector, jurisdiction-independent AML baseline check alongside their country-specific gates.

GATE CATALOG · REGULATORY DETERMINATION DOMAIN

gateAML

gateAML determines encoded anti-money-laundering conditions, customer/party state, transaction context and escalation dependencies. The gate contributes a bound regulatory determination state; it creates neither regulatory authority nor Execution Permission.

DOMAIN_DETERMINATION_ONLY = true · EXECUTION_AUTHORITY = false · EXECUTION_PERMISSION = false
gateAML regulatory determination domain
AUTHORITY BOUNDARY

AML STATE IS NOT EXECUTION AUTHORITY.

CAN

  • deterministically evaluate encoded regulatory conditions
  • bind determinations to source, scope, time and input state
  • surface missing, expired or conflicting regulatory dependencies
  • produce attributable evidence for the concrete determination

CANNOT

  • replace a regulator, supervisor, court or competent institution
  • create legal or regulatory authority through score, consensus, AI or administration
  • turn a gate PASS into an Execution Right on its own
  • mint an ExecutionCapabilityToken on its own
REGULATORY STATE

Regulatory determination is evidence. Not regulatory authority.

SOURCE

Authoritative source

The relevant rule must originate outside the system from a legitimate normative or institutional source.

SCOPE

Defined matter

The determination is limited to the encoded subject, entity, transaction or operation under review.

TIME

Point-in-time state

Effective dates, transition periods, expiry and version state remain explicit.

INPUT

Canonical input

A reproducible determination requires a defined canonical input state.

DEPENDENCY

Dependencies

Missing or contradictory dependencies remain visible rather than being converted into invented permission.

EVIDENCE

Bound evidence

The resulting state can be bound to source, input, scope and time for later verification.

RELATED DETERMINATION DOMAINS

Regulatory domains compose. They do not confer authority on one another.

Only scope-relevant determinations become dependencies in Execution Rights resolution. The links shown are not a universally mandatory sequence.

EXECUTION RIGHTS

Five dimensions. Regulatory state can inform them; no gate replaces them.

AAUTHORITY
RRULE
JJURISDICTION
TTIME
DDEPENDENCY
ALL FIVE REQUIRED DIMENSIONS VALID → VALID EXECUTION RIGHT · ANY REQUIRED DIMENSION ABSENT → NO VALID EXECUTION RIGHT → NO CAPABILITY → NO EXECUTION
INVARIANT

A regulatory PASS is a determination. Never a permission by itself.

AUTHORITY → DETERMINATION → EXECUTION RIGHTS → CAPABILITY OR NONE → EXECUTION OR NONE → EVIDENCE

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