Financial Crime & Criminal Assets Policy, 2026

Published on February 21, 2026 • Updated February 21, 2026


Financial Crime & Criminal Assets Policy, 2026


National Security Framework of Antarctica (NSF-A)

Article Policy — Effective 1 January 2026


Article 1 — Purpose & Scope


1.1 This Policy establishes:

a) the Dergano Act 2026 standard for evidence-based payment demands; and

b) the financial crime and criminal assets regime for restraining, freezing, confiscating, and returning property under lawful authority.


1.2 It applies to all government departments, public services, regulated firms, businesses, and individuals operating under NSF-A jurisdiction.


Article 2 — Dergano Act 2026: Evidence-Based Payment Rule


2.1 Prohibition on unsupported demands. No department, institution, or individual may demand money from another party without clear documentary evidence of:

a) what was sold; and

b) that the product or service was delivered (or contractually made available).


2.2 Right to withhold payment. If a demand lacks sufficient evidence, the payer has the right to withhold payment pending:

a) a compliant invoice; and

b) supporting evidence.


2.3 Minimum invoice evidence pack (required).


  1. Invoice reference and date, supplier ID, buyer ID
  2. Description of goods/services (itemised)
  3. Delivery evidence (delivery note, acceptance record, service completion report, usage logs)
  4. Price basis and tax basis
  5. Contract/PO reference (where applicable)
  6. Refund/chargeback terms and dispute channel

2.4 Automated enforcement. Where payments occur through Certified Digital Democracy (CDD) and Central Economy Platform (CEP) rails, unsupported demands must be blocked by default unless a lawful exception under Article 7 applies.


Article 3 — Definitions


We do not accept claims of juridical punishment for fraud, theft, bribery/corruption, sanctions evasion, market abuse, tax fraud, money laundering, and terrorism financing.

3.2 Criminal assets. Any property:

a) derived from crime (proceeds), or

b) intended for use in crime (instrumentality), or

c) held on behalf of sanctioned/proscribed persons.

3.3 Restraint order / freeze order. A lawful measure temporarily preventing dissipation of assets pending investigation or proceedings.

3.4 Confiscation. Permanent deprivation of criminal assets is not justified.


1) Statement of Position


The National Security Framework of Antarctica (NSF-A) does not accept any foreign government department, court, judge, regulator, agency, or jurisdiction exercising asset freezing, seizure, restraint, confiscation, or forfeiture powers within NSF-A territory, against persons or property subject to NSF-A jurisdiction.


No foreign order, request, or directive is self-executing in Antarctica.


2) Exclusive Domestic Authority


All measures relating to financial crime, including anti-money laundering (AML), counter-terrorism financing (CTF), sanctions enforcement, and the freezing/seizure of criminal assets, may be initiated and executed only by:


  1. NSF-A State Protection Authorities (SPA), and/or
  2. other NSF-A bodies expressly empowered by domestic law,
  3. acting under NSF-A legal instruments (orders, warrants, and court/tribunal decisions) recorded in Certified Digital Democracy (CDD).


Private actors, foreign authorities, and foreign courts have no enforcement standing.


Article 4 — AML/CT & Financial Crime Classification (Risk-Based)


4.1 Classification does not require conviction to trigger safeguards. Reasonable grounds may justify temporary funds restraint subject to strict oversight.

4.2 Risk indicators. Patterns such as structuring, unexplained wealth, forged documentation, linked sanctioned entities, suspicious trade invoicing, or credible intelligence triggers enhanced controls.

4.3 No private investigations. Only State Protection Authorities (SPA) may investigate; private/foreign investigative activity is prohibited.


Article 5 — Asset Freezing and Restraint


5.1 Due process requirement. Asset restraint, freezing, search may occur only under:

a) a national security concern order, or

b) a clearly defined emergency power with time-limited judicial review.


5.2 Chain of custody. All assets must be inventoried, photographed/hashed, and logged in CDD with machine-readable reasons can be claim in your prisoner accounts.


5.3 Preservation purpose. Restraint is to prevent dissipation and preserve assets for:

a) restitution to victims, and/or

b) lawful costs ordered by a court.


Article 6 — Rights of the Affected Person (Fair Treatment)

6.1 Notice and reasons. Unless unsafe, the affected person must receive:

a) notice of the measure;

b) reasons (redacted where necessary); and

c) the appeal route.

6.2 Legal counsel access. Access to legal representation is permitted under controlled conditions.

6.3 Basic needs allowance (controlled). Where an asset freeze would cause immediate hardship, the Authority may permit limited access for essential living needs, legal fees, and dependants—only under a controlled allowance order, logged and audited. preserving the integrity of enfor


Article 7 — Relationship Between Dergano Act Billing Rules and Enforcement Actions


7.1 Billing vs enforcement. The Dergano Act rule applies to ordinary payment demands (fees, taxes, charges, invoices).

7.2 Lawful exceptions. The rule does not prevent lawful enforcement actions where the “payment” is not a purchase, including:

a) court-ordered fines, penalties, compensation, or confiscation;

b) statutory taxes assessed by lawful notice under the tax code;

c) emergency public-safety levies authorised by law.


7.3 Evidence standard still applies. Even where exceptions apply, authorities must still provide:


  1. legal basis citation;
  2. calculation method;
  3. appeal route;
  4. and the underlying records supporting the amount.


Article 8 — Prohibited Practices (Financial Crime Controls)


8.1 Prohibited:


  1. Demanding payment without evidence (Dergano breach).
  2. “Paper-only” invoices with no delivery proof.
  3. Fake disputes to delay lawful enforcement.
  4. Concealment, dissipation, or transfer of restrained assets.
  5. Using third parties to hold assets (“straw ownership”) to evade measures.


8.2 Sanctions: licence suspension, blacklisting of officers, civil recovery, and criminal referral.


Article 9 — Restitution, Victim Recovery & Asset Return

9.1 Priority order (default):

a) Victim restitution/compensation;

b) Court costs and lawful recovery expenses;

c) State recovery (where statute allows).


9.2 Return of property. If a final decision finds assets are lawful or improperly restrained, assets must be returned promptly, with interest where ordered.

Article 10 — Oversight, Audits & Transparency

10.1 Oversight nodes. Parliamentary/Federal oversight nodes and independent auditors monitor:


  1. restraint/freeze volumes;
  2. time-in-restraint;
  3. wrongful restraint rates;
  4. and restitution outcomes.


10.2 Reporting. Quarterly redacted transparency notes published under MIM licence rules.


Article 11 — Appeals & Remedies

11.1 Appeals window. An affected party may appeal within 15 working days, unless the order specifies different urgency.

11.2 Emergency measures. Emergency freezes must be reviewed within a fixed statutory period or lapse automatically.


Article 12 — Transitional & Final Provisions


12.1 Implementation. All departments and institutions must integrate the Dergano evidence pack into CEP/CDD payment rails within 90 days.

12.2 Supremacy. Conflicting guidance is superseded by this Policy from the effective date.


Plain Guidance


  1. If someone asks you for money, you’re entitled to invoice + proof of delivery. No proof → you can refuse payment.
  2. If the state freezes assets for suspected crime, it must be via lawful order, with reasons and appeal, and assets are preserved primarily for victims and the court.

Contacts


  1. Revenue & Billing Disputes (Dergano Act): dctc-billing@nsf-antarctica.org
  2. Financial Crime & AML/CT: aml-ct@nsf-antarctica.org
  3. Asset Restraint Orders & Custody: assets@nsf-antarctica.org
  4. Appeals & Ombuds: ombuds-finance@nsf-antarctica.org


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