- Who are your clients’ Ultimate Beneficial Owners (UBO)?
- Are there any Politically Exposed Persons (PEP) associated with your clients?
- What are the nationalities of the individuals associated with your clients?
- Do you have up-to-date copies of passports and identification papers?
- Did you carry out any face-to-face interviews with your customers?
- Is an adequate process of risk assessment being maintained?
- What level of risk management is being adopted?
- Do you have an updated structure chart on file?
- Who are your introducers/intermediaries and what jurisdictions do they operate from?
- When did you last check your client base against sanction lists?
- How do you enforce an AML risk policy across your organisation?
These questions pose a number of challenges which need to be addressed.
Challenge #1: Store Client Information
To be able to be on top of things with AML, you need to ensure that all the client information is in ONE place and is secure, easy to access, complete and up-to-date.
Challenge #2: Onboarding Clients
Onboarding new clients must be seamless for the client, but not at the expense of compliance. You also need to consider that you may not have all the information on hand on day 1, while ensuring that all information is collected, eventually.
Challenge #3: Structure Charts and UBOs
The selected technology should assist in the preparation of a structure chart and be able to identify UBO percentages in complex structure charts. It also needs to have the ability to build the same structure charts over and over again.
Challenge #4: Risk Assessments
Risk assessments need to be carried out in a timely manner, both periodically and as soon as possible when changes arise. Such assessments ensure that your company’s risk policy is adhered to.
Challenge #5: Statistical Reporting
Management or regulatory authorities may request regular information including:
- How many individuals and legal entities do you provide services to?
- How many PEPs from countries in the EU do you service?
- How many of your relationships are not face-to-face
- A snap shot of your customers risk tiers
Your AML solution should have the ability of producing this information easily when required.
Challenge #6: Ad-hoc Reporting
Besides regular reporting, your selected system needs to be able to provide information requested on an ad-hoc basis by regulatory authorities or senior management.
Challenge #7: Regulator-Compliant Database
Your data needs to be organised according to the requirements of local regulators and should be flexible enough to be updated when new requirements arise.
Challenge #8: Expiring Documentation
Besides acting as a repository for documents, any AML solution should also ensure that such documents are not expired and alert the customer to produce updated documentation before these do expire.
Challenge #9: Ongoing Sanction Checks
Your AML solution should constantly check your database against UN/EU sanctions and allow you to search your client-base against third-party PEP and Adverse Media databases.
Challenge #10: PEP register – Ensure you have a PEP register.
InScope-AML is a comprehensive and secure tool for all your AML and KYC needs which puts you in control through an end-to-end automated system, providing you with a 360-degree view of the customer. It also ensures that you are covered for any challenges arising from the AML and KYC process.