Overview

The Transaction Screening Policy allows you to define which transactions to screen. When Fireblocks screens a transaction, it sends the transaction's details to your Anti-Money Laundering (AML) provider for risk analysis, AML/Counter Financing of Terrorism (AML/CFT) monitoring, and sanctions monitoring.

Fireblocks screens incoming and outgoing transactions to ensure compliance with transactional AML/CFT rules and sanctions. Fireblocks performs three types of screening operations:

• Screen deposits to Fireblocks: Fireblocks registers deposits to your workspace with your AML provider for risk analysis. You can choose to pass, screen, or freeze these transactions.
• Screen withdrawals from Fireblocks: Fireblocks receives risk information on the destination address before the withdrawal. You can choose to pass, screen, or freeze these transactions.
• Screen transaction data for registration with AML provider: Fireblocks registers completed transactions with your AML provider for further analysis. This can be specific venue combinations, such as vault account to vault account, or a manual re-screen of a specific transaction.

Default policy vs. custom policy

By default, the Transaction Screening Policy requires all transactions to be screened, including internal transactions. However, you can replace the default Transaction Screening Policy with a custom policy that defines which transactions are screened.

Custom policies operate on a first-match basis rule set. This means the first rule that matches the transaction’s parameters is applied to the transaction and the action specified in the rule is performed. If there is no matching rule, the transaction is not screened and is accepted automatically.

Building your Transaction Screening Policy

To get started, download the AML Transaction Screening Policy template and read the instructions on the Instructions tab. Then build your policy using the rule parameters below.

Rule parameters

Source

This is the transaction's source. You can select one of the following values:

• Any
• Vault Account (e.g., Default vault account)
• Any Vault Account
• Exchange (e.g., Binance, Coinbase)
• Any Exchange
• Unknown—used for non-whitelisted external addresses
• Network connection
• Any Network connection
• Any Unmanaged Wallet—used in conjunction with a Customer Reference ID

Source Subtype

When you select a specific source type, such as Vault Account or Exchange, you must enter the name of the source in this field.

Leave this field blank when you select an "Any" source type.

Destination

This is the transaction's destination. You can select one of the following values:

• Any
• Vault Account (e.g., Default vault account)
• Any Vault Account
• Exchange (e.g., Binance, Coinbase)
• Any Exchange
• Network connection
• Any Network connection
• Any Unmanaged Wallet—used in conjunction with a Customer Reference ID
• One Time Address

Destination Subtype

When you select a specific destination type, such as Vault Account or Exchange, you must enter the name of the destination in this field.

Leave this field blank when you select an "Any" destination type.

Amount/AmountUSD

This is the asset quantity or dollar amount a transaction’s value must be higher than to trigger the rule. You can enter one of the following values:

• Amount: The quantity of an asset. When you create rules using asset amounts, this field's asset value and the Asset field's value must match (e.g., > 0.01 ETH, ETH).
• AmountUSD: The US dollar amount (e.g., > $200).

Asset

This is the asset to which you want to apply the rule. You can specify a single asset by entering it as its AssetID on Fireblocks, or you can enter Any to apply the rule to all assets in your workspace.

Make sure to list only assets your AML provider supports.

Action

This is the action Fireblocks performs when the rule is triggered. You can select one of the following:

• Screen: Screen the transaction and submit its details to your AML provider for risk analysis and monitoring.
• Pass: Skip screening and accept the transaction.
• Freeze: Freeze the transaction’s assets in your workspace so they cannot be spent. Remember, transactions frozen by this action need to be unfrozen manually by an Admin-level user.

Comments

This field is optional. Use it to add any rule-specific information you want Fireblocks Support to be aware of when you submit your policy for review and implementation.

Example policy

1. Skip screening on internal vault account-to-vault account transactions.
2. Screen any incoming transactions to the Default vault account.
3. Screen any incoming BTC transactions from any Binance account to the Vault 2 vault account.
4. Screen any outgoing ETH transactions greater than 0.01 ETH to the unmanaged wallet address 0x5…394.
5. Screen any outgoing BTC transactions from the Default vault account.
6. Screen any incoming ETH transactions greater than $200 from any exchange.
7. Skip screening on all other transactions.

Uploading your Transaction Screening Policy

To upload your workspace’s AML Transaction Screening Policy, go to Settings > Compliance and select your AML provider. Then select Change policy in the Screening row, and upload the template with your custom policy.