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Client CDD Workflow

The workflow can be used to perform Client Due Diligence (CDD) on companies, trusts, estates, individuals and Partnerships

Updated over 10 months ago

Undergoing CDD Tab

All of your clients that have not completed CDD in Firmcheck will appear in the Undergoing CDD tab. After completing the AML Workflow, the entity will be moved to the ‘Completed CDD’ tab.

You can apply filters to the workflow in the left-hand column to view the clients' list by:

  • Reason for CDD

  • Scheduled to complete

  • Review status

  • Level of CDD

  • Level of risk

  • Client type

  • Business unit

  • Partner

  • Manager

Within the ‘Undergoing CDD’ page of the AML Compliance tab, search for, then click on the name of the entity you would like to perform a CDD check on. A slide-out form will appear which provides the information you need to capture.

Client Information

1. If the entity is a Company that was imported from the Companies House, most fields in this subsection will already be populated. If you have created the entity manually, the information displayed is dependent upon the information entered.

It is recommended to select the tick box Copy information from the profile

2. You also have the option to enter additional notes and attach any supporting documents.

3. Once you have checked all the information is correct and made any amendments, select the tick box at the bottom of the page "This section has been completed", and click Update.

CDD Candidates

1. A list of the parties associated with the prospect will appear here.

2. Next, to the names of the parties you would like to include in the entity's CDD, select the AML-relevant relationship. Relationships that can be selected are:

  • Authority to act

  • Exercises significant or control

  • Individual on whose behalf a transaction is being conducted

  • >25% ownership

  • >25% voting rights

  • Exercises ultimate control over management of the entity

  • Other control

Where the prospect is an individual, the individual is automatically selected as a CDD Candidate (flagged as ‘Client’) and cannot be removed.

NB. If candidates are missing from the list of CDD candidates, you will have to navigate back to the entity's edit profile to add in the required parties.

Important

If more than one copy of an individual appears in the list return to your Clients>People tab, search for the person and Merge Duplicate Contacts before proceeding with the next step.

3. As you add candidates they will form a list that displays their roles within the entity and the reason for performing CDD.

4. When you are satisfied that the correct people appear in this list, select the tick box at the bottom of the page "This section has been completed", and click Update.

Note: As you progress through the steps you will notice that ticks begin to accumulate next to each section. This will only occur when it has been marked as complete. If you want to come back to complete a section later simply update in the bottom right without selecting "This section has been completed". The section will remain un-ticked until updated.

Perform CDD

1. A list of the CDD candidates will appear with the following to be completed:

  • Identity verification - collect and verify the Legal name, Date of Birth, and Residental address (Legal name, UKCH (or identifying number) and Registered address of non-natural candidates)

  • AML/CFT relationships - Record and provide evidence of Beneficial ownership information and confirm the Authority to act on behalf of the client

  • Politically exposed person (PEP) and Personal source of wealth - Determine whether the candidate is politically exposed and provide evidence of the source of funds for the candidate if required. (PEP is non-applicable for a non-natural entity)

Select ‘Update’ next to each of the above-mentioned sections to add information (or “collect and verify” for the identity verification section).

2. If the evidence from a prior determination displayed is correct you can select "Use this".

3. If a person's identity information needs updating or does not have an ID determination appearing, select "Collect & Verify" to make a new determination. You can also update the "Politically exposed person (PEP) and Personal source of wealth".

4. Once all parties are updated and ticked, this section is completed automatically.

Source of Funds

Once the ‘Perform CDD’ section has been completed, you can now move on to the ‘Source of funds’ section of the workflow.

You can enter information and attach documents for the Source of funds and Source of wealth. Such as tax returns or sale & purchase agreements.

Click update once this section has been completed.

Risk Assessment

When your firm is created in Firmcheck, you have the option of selecting the appropriate risk question set that your firm follows for AML/Onboarding compliance. These questions appear in the ‘Risk Assessment’ section

1. Select all activities which apply to this entity, or add your notes in the "other" field.

2. Under the checklist, there is a risk exposure dropdown. Having determined the areas of risk, assign an overall risk rating for this client.

  • Low

  • Medium

  • Medium-High

  • High

Click update once this section has been completed.

Level of CDD

1. Recommended, scheduling a due date for the completion of CDD.


2. Select the Level of CDD to perform. Based on the outcome of your risk assessment you can select from:

  • Simplified

  • Standard

  • Enhanced

You can enter notes supporting your decision to adopt the given level of CDD.

Once you have filled out all the details on this page, click Update.

The 'Review' section allows you to review all the activities recorded for the entity.

Review

AML determination

The AML determination will give you an overview of the information entered into the workflow. The following areas are listed and the commentary is noted.

  • NAME

  • TYPE OF ENTITY

  • INCORPORATION

  • ADDRESS

  • LEVEL OF CDD

  • SOURCE OF FUNDS

  • SOURCE OF WEALTH

  • LEVEL OF RISK

  • IDENTIFIED RISKS

Any sections not completed will appear with a warning advising it is not yet recorded/determined.


CDD candidates and identities

All of the parties associated with the workflow and their documents are listed in CDD candidates and identities. Each party is separate and the ID evidence shows all the documents used to make the determination.

  • Name of entity (Person, Trust or Company)

  • Role(s) within the entity

  • AUTHORITY TO ACT

  • QUALIFIERS

  • RELATIONSHIP

  • PEP STATUS

  • DATE OF BIRTH (Not applicable for Trust or Company)

  • ADDRESS

  • ID EVIDENCE

Any sections not completed will appear with a warning advising it is not yet recorded/determined.

Attachments

All documents are listed, you can download one document or all documents.

Schedule the next review

Perform the next review in

  • The default period (One year)

  • Six months

  • One year

  • Two years

  • Three years

  • Five years

  • Custom period

Click update once this section has been completed.

AML/CFT determination

Once you have completed the CDD workflow, the Compliance Office can log into Firmcheck. In the 'Review status' filter, select Second review, this will populate all those entities ready for Second review and confirmation.

  • Proceed

  • Do not proceed

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