Starting the AML Process
You can begin the AML process for your clients in several ways
When you add a client manually, there is an option to "Save client and start AML"
Select the clients tab from the top navigation bar, locate your client and then click on the menu button on the right-hand side of each client. From here you can select "Start AML"
Select the work tab from the top navigation bar, In the "To-Do" section, you'll see a “Start AML” button next to your client's name.
In the section, you will find four tabs: Client Profile, Client Information, Risk Assessment, and Verifications.
Client Profile
Client Profile
Client Details
This section allows you to review and edit the generic details for the client (important to add services)
Confirm related parties to include in CDD
Confirm the individuals (or associate businesses) and the CDD reasons to include in the AML checks
Client Information
Client Information
Nature of business
What type of business is the client operating (Coming Soon - this section will be prepopulated from the SIC code at Companies House)Additional notes
Any relevant notes you want to contribute to the AML determination evidenceSupporting Documentation
A generic document area to may wish to use to contribute to the AML determination evidence (Letter of Engagement, Onboarding questionnaires etc) NOT ID DOCSAdditional due diligence
If needed, you can add "Source of funds" and "Source of Wealth" information by selecting the "+" option
Risk Assessment
Risk Assessment
Risk Assessment templates
Can be managed from the global firm settings areaSelecting "Yes" to any question
This will open up a dedicated section to add your commentary on the Risks identified and mitigation actions. This will also call out the risk identified on the AML Summary on the right-hand side, as well as the Firm-wide risk assessmentSelecting "No" to any question
Will not require any further information from you. For efficiency, you have the option to set all unanswered questions to "No" at the top.Save risk assessment
You must save the risk assessment as the bottom of the page to progress through the AML process. The risk assessment can be edited at any time before making the final declaration.
Verifications
Verifications
This is where you can store, review and conduct ID verification and other AML checks that are required by your supervisory body.
More in-depth support about each check can be found here
Complete ID Verification
Once you upload your client's ID documentation and/or run electronic searches, you will receive "tick marks" against the verified information.Override verification
You do have the opportunity to override the verification decisions to progress with the AML process if needed. You can do this by selecting the edit icon underneath your client's name (highlighted in red below) and changing the outcome
AML Summary & Review
In this section, you'll determine and select the client's risk level, choose the appropriate CDD level, and set the next review date.
Once you’ve reviewed all parts of your client's AML, including the overall CDD level and risk level, it’s time to set the next review date. By default, it’s set to 12 months, but if you’d prefer something different, just click the pencil icon and choose your custom date.
When you're ready, scroll down and click “Go to review.” You can approve the AML review or choose multiple reviewers—like a partner of the firm or MLRO.
On submission, assigned reviewers will receive a notification to review and confirm CDD decision. Once all reviews have been completed, the AML record will be completed.