Compliance Programme

A key objective of Buna is ensuring compliance with Sanctions and Anti-Money Laundering / Counter Terrorism Financing (AML/CTF) standards and thereby supporting its Participants in enhancing their compliance levels.


Buna Financial Crimes Compliance (FCC) programme is based on three key pillars to promote the safety and efficiency of its operations and to ensure sufficient controls and measures are implemented:


Governance, Roles and Responsibilities

Sound governance and robust organizational capabilities with clear roles and responsibilities delineated between Buna’s System Operator and Participants.


Participants Onboarding Due Diligence

Measures for due diligence and screening of Participants prior to onboarding onto the system. Only financial institutions who adhere to AML/CTF, anti-corruption, sanction screening, and all other compliance requirements with adequate capabilities to detect and act on suspicious activities, will be accepted to join the Buna payment system.


Controls and Processes

AML/CTF control, processes, and procedures to detect, investigate and act on Sanctions hits and/or suspicious transactions in the payments submitted for settlement in Buna.

Through this programme, the Organization offers an additional layer of Compliance checks both before and after the settlement of any transaction that goes through the Buna payment system.


Step 01


Step 02


Step 03


Roles and Responsibilities

Buna, its Participants, and the Fund Holding Institutions (FHIs) have specific responsibilities with respect to enforcing the compliance process within the system.

Participants are accountable for complying with and performing mandatory compliance obligations against currency-specific and international laws and regulations. Participants ultimately remain accountable and responsible for adhering to applicable compliance regulations.

The Fund Holding Institutions (FHIs) are the Central Banks of the respective eligible currency or designated commercial banks. In their capacity as FHI’s, the Central Banks of the respective eligible currency enforce their regulations by participating in the development of the participation eligibility criteria with respect to their currency. The designated commercial bank to conduct the role of an FHI is not responsible for the checks of transactions settled in Buna.

Buna, as the system established and operated by the system operator for the settlement of payments between the participants of the system, is responsible for providing a second layer of compliance checks to ensure that both originating and receiving banks or other financial institutions have successfully performed their obligations and exerts reasonable efforts to identify and suspend any suspicious payment submitted for settlement through its platform.

Participants KYC and Due Diligence

Buna ensures a sound participant ecosystem by restricting participation to those entities that are duly regulated and licensed in their country of origin and/or any other jurisdiction where they provide services. Buna designs, implements, and monitors a set of controls, processes, and procedures to ensure that participants have a sound compliance framework. The review of the participants’ compliance practices is done during the onboarding and will be subject to regular reviews.


Controls and Processes

Buna undertakes pre-payment checks of all transactions, which include transaction completeness, sanctions screening, and pre-payment fraud detection, complementary to the continued checks conducted by sending and receiving institutions. Buna also conducts post-payment checks which include post-payment fraud detection as well as transaction monitoring to detect fraudulent behavior or suspicious activities.

Buna aims to achieve Straight-Through Processing (STP) by standardizing payment message formats and information requirements, ensuring transaction completeness, and automating processes. The screening of transactions is automated and in real-time, supported by an in-house compliance team to investigate sanctions hits, fraud attempts, and suspicious transactions.