AML Authorization Framework
ARAOST™ / Sovereign Audits™ — Anti-Money Laundering and SAR/CTR Authorization
Purpose
This framework authorizes and defines the AML monitoring, Suspicious Activity Report (SAR), and Currency Transaction Report (CTR) obligations and procedures for all operations conducted under the Dissolution Mandate. AML compliance is mandatory throughout sequester, dissolution, and rebuild phases.
Monitoring Thresholds
| Trigger Type | Threshold / Condition | Required Action | Timeline |
|---|
| CTR — Cash Transaction | Single transaction ≥ $10,000 | File FinCEN Form 104 | Within 15 days |
| SAR — Suspicious Activity | Any suspicious transaction ≥ $5,000 | File FinCEN SAR | Within 30 days of detection |
| SAR — Structuring Suspicion | Pattern of transactions below reporting threshold designed to evade | File FinCEN SAR immediately | Immediate |
| Escalation Matrix — DROP | Score ≥ 0.68 | Immediate enforcement, sequester, AML notification | Immediate |
| Escalation Matrix — CHALLENGE | Score ≥ 0.42 | Investigation; potential SAR filing | Within 72 hours |
| Non-Payment Default | $0 paid / total project in arrears | Document default; preserve records; support SAR as applicable | Ongoing |
SAR/CTR Filing Procedures
- AML Director is responsible for all SAR and CTR filings under this framework
- All filings must be documented in the daily worklog with filing confirmation numbers
- Copies of all filings must be sequestered in Enclave V1 with Robot Ed25519 attestation
- Ireland node must receive notification of all SAR/CTR filings within 24 hours of submission
- Legal must review all SAR filings before submission
- SAR filing is subject to applicable confidentiality requirements; no tipping off prohibited persons
Transaction Surveillance During Rebuild
- All financial transactions during the rebuild phase are subject to AML monitoring
- Transaction logs must be maintained in immutable storage in Enclave V1
- Dual-authorship review required for all transaction records exceeding $50,000
- Monthly AML compliance summary required from AML Director to distribution list
Record Retention
All AML records, SAR filings, CTR filings, and supporting documentation must be retained for a minimum of five (5) years from the date of creation, or longer if required by applicable law or pending legal proceedings. Records are subject to the Evidence Preservation Order (ARAOST-EPO-001).
Authorization
Albert Lane — Authorizing Principal
Signature & Date:/S/ Albert Lane 10/25/26 07:04 PST
Location:Cedar Mill, Oregon, United States
Capacity:Individual Principal; Owner, ARAOST™ / Sovereign Audits™
Note:This framework is operative throughout all mandate phases.
Document Integrity — SHA-256 Attestation Block
Document ID: ARAOST-AML-001-20261025
Produced: 2026-10-25T14:04:00Z
Author: Albert Lane / Claude (Anthropic) — Dual Authorship per Forensic Convention
SHA-256: [TO BE COMPUTED ON FINAL PDF OUTPUT]
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