Why This Matters: A financial forensics company that helps clients detect money laundering must itself be above reproach. This policy demonstrates that Knemonik applies the same rigorous standards to its own client intake that it applies to the subjects of its investigations. We do not knowingly work with sanctioned entities, criminal enterprises, or individuals seeking to weaponize our services.
Knemonik LLC is committed to full compliance with applicable US anti-money laundering laws and regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, the Anti-Money Laundering Act of 2020, and all regulations promulgated by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC).
While Knemonik is a financial intelligence firm and not a financial institution subject to mandatory AML program requirements, we voluntarily adopt these standards because our services intersect with the detection, reporting, and investigation of financial crimes. Operating to a higher standard protects our clients, our staff, and the integrity of the US financial system we serve.
This policy applies to:
All prospective clients are assessed against Knemonik's Client Risk Framework prior to engagement commencement. Clients are classified into three tiers:
Regulated institutions, licensed law firms, publicly traded companies, US government agencies. Standard intake process. Engagement may proceed promptly.
Private individuals, small businesses, foreign entities, anonymous whistleblowers. Standard OFAC screening + purpose review. Engagement proceeds pending clearance.
High-risk jurisdictions, PEPs (Politically Exposed Persons), previously flagged entities, unusual engagement patterns. Senior review required before acceptance.
For all Tier B and Tier C engagements, Knemonik collects the following minimum information prior to commencement:
Knemonik does not require government-issued identification for all engagements. However, the scope and nature of the requested services, the identity of the subject of investigation, and the stated purpose must be sufficiently clear for Knemonik to assess legitimacy and compliance with this policy.
Every prospective client is screened against the US Treasury OFAC Specially Designated Nationals (SDN) list and the Consolidated Sanctions List before engagement commencement. Screening is performed using Knemonik's proprietary OFAC screening engine, which is refreshed against the official US Treasury XML feed within 24 hours of any update.
Knemonik will not engage any client that:
Regardless of client risk tier or sanctions status, Knemonik will decline any engagement where the requested services could facilitate:
Any Knemonik team member who identifies an engagement that may violate this policy must immediately escalate to senior management. No engagement may proceed, and no retainer may be accepted, until the escalation is resolved.
Knemonik reserves the right to terminate any engagement, at any time and without refund of fees paid, upon determination that the engagement violates this policy or applicable law.
During the course of an engagement, Knemonik analysts are trained to identify patterns that may indicate that a client is misrepresenting the purpose of the engagement. Such patterns include:
Upon identifying such patterns, the assigned analyst will escalate the matter. Depending on findings, Knemonik may file a Suspicious Activity Report (SAR) with FinCEN as permitted by applicable law.
Knemonik maintains the following records for a minimum of five (5) years from engagement close, or as required by applicable law:
All Knemonik personnel involved in client intake, engagement delivery, or financial analysis receive AML/KYC training at commencement of employment and annually thereafter. Training covers applicable US laws, this policy, red flag recognition, escalation procedures, and whistleblower protections for employees who report policy violations.
This policy is owned and maintained by Knemonik's Chief Compliance Officer (or, prior to appointment, the Chief Executive Officer). The policy is reviewed and updated at least annually and upon any material change in applicable law, regulation, or business activity. Questions regarding this policy should be directed to support@knemonik.com.
This policy is governed by the laws of the United States of America and the State of Delaware. Knemonik cooperates fully with competent US law enforcement and regulatory authorities.