🛠️ How to off-board a client
Off-boarding a client in Firmcheck
This feature used to be called Archive.
When your relationship with a client has ended, you are still required to retain that client’s AML records for up to seven years after the relationship has concluded.
Firmcheck’s Off-board feature is designed for clients you no longer act for. It lets you retain historical AML records without keeping the client in your active client list.
Off-boarding should not be used for clients where you still have an ongoing business relationship or continuing AML obligations.
Off-boarding cannot be undone. The live client record is removed and cannot be restored, although you can re-onboard the same company later as a new client.
When should I off-board a client?
You should only off-board a client when your firm no longer acts for them and the business relationship has ended.
You should generally keep a client active if:
you still act for them
they may need a future AML review
you need to maintain an up-to-date view of their AML status
they have related parties you want to keep connected to the client record
you want them, or their related individuals, to benefit from ongoing Watchlist monitoring
Keeping clients active can help support your ongoing AML compliance processes between formal reviews.
Why keep a client active?
Keeping a client active in Firmcheck can help you maintain continuity of AML records and ongoing compliance oversight.
For example, individuals can be added to Watchlist monitoring, where Firmcheck runs daily checks on everyone in your Watchlist and highlights any matches for review.
This can be useful for ongoing monitoring between periodic reviews, including where a client or related individual may need to be checked for sanctions, PEPs, adverse media, or other watchlist matches.
Learn more: How to enable Watchlist monitoring
Before you off-board a client
Before off-boarding a client, make sure the client relationship has ended and you no longer need the client to remain active in Firmcheck.
Once a client is off-boarded:
a read-only record of their AML history and verification records is kept in your off-boarded clients list
the live client is removed, along with the individual and organisation records behind them, unless another active client still relies on them
they are no longer treated as an active client
the action cannot be undone
If you still act for the client, keeping them active may better support your AML compliance.
How to off-board a client
1⃣ Navigate to the client profile
2⃣ Click the three dots next to the purple AML button
3⃣ Select Off-board this client
You will then be asked to type the word FREEZE into the text box. Once you click Confirm off-boarding, you are taken to your off-boarded clients list, where the client’s read-only record is kept.
What happens after off-boarding?
After a client is off-boarded:
a read-only record of the client’s AML history and verification records is kept in your off-boarded clients list
the live client is removed, along with the individual and organisation records behind them, unless another active client still relies on them
the client is removed from your active client list
the client is no longer included in your active subscription charges
the action cannot be undone
If you later act for the client again, you can add the company again as a new client. The new record starts fresh, so you will need to complete AML again, and the off-boarded record stays in your off-boarded clients list.
Clients currently on Archive
If your firm still has clients on Archive, they can remain archived.
However, once removed from Archive, they:
cannot be re-archived
will need to be moved to off-boarded instead
FAQs
Can I off-board a client and reactivate them later?
No. Off-boarding cannot be undone and the live client record cannot be restored.
If you start acting for them again, you can add the company as a new client. Previously an off-boarded client blocked you from adding the same company number a second time, which is no longer the case. The new record starts fresh, so any required AML work will need to be completed again.
Should I off-board clients who are due for review later?
Not if you still act for them or have continuing AML obligations.
Keeping the client active helps preserve continuity of AML records and allows you to use active-client features such as Watchlist monitoring.
Does off-boarding remove AML history?
No. A read-only record of the client’s AML history and verification records is kept in your off-boarded clients list, and remains your full record for retention purposes.
The live client is removed, along with the individual and organisation records behind them. Anything another active client still relies on is kept.
Will off-boarded clients still be included in subscription charges?
No. Once a client has been off-boarded, they are no longer treated as an active client for subscription purposes.
However, off-boarding should only be used where the client relationship has ended.
Can Watchlist monitoring help with overseas individuals?
Yes. Watchlist monitoring can still provide value where UK-specific data sources are limited, because it runs ongoing daily checks on monitored individuals and highlights matches relating to sanctions, PEPs, adverse media, or other watchlist results.
How can I see off-boarded clients?
Navigate to the Clients page > select the Actions drop-down menu > select Off-boarded clients. You will see a filtered view showing your off-boarded clients, and you can click through from there to review any AML history and verification records.