1. Starting the AML process
If the individual already exists on the system, you can start an AML for them via the individual’s details page. Using the “Start AML Only” button on the Progress tab.
If the individual does not yet exist, you can create the individual and the AML process either via your Dashboard or the Engagements section. Via the “New Engagement” button.
2. Identification required
If you have the identification documents to hand, you can upload them via the “Upload” button either on the Progress or Identification Documents tabs.
If you require the individual to provide them, you can use the “Email form” button on the Progress tab. You will be notified via email once the individual has uploaded them and the AML will proceed from this step.
3. Creditsafe check
You can begin the Creditsafe process by using the “Start Creditsafe” button on the Progress tab.
Ensure the personal, address and identification details are correct, then use the “Send to Creditsafe” button on the last page.
4. Review Creditsafe
Note: If the Creditsafe result was a pass this step will be skipped.
In the event of a referred Creditsafe result, administrators have the option of running the Creditsafe again with revised details, via the “Re-run Creditsafe” button.
Managers and above have the option of using the “Review Creditsafe” button on the Progress tab. This will open the Creditsafe tab which provides a list of the reasons for the referred result. You can provide an explanation/comment against each of the reasons and use the “Submit review” button at the bottom to complete the review.
5. Risk assessment
Note: This step can only be completed by managers and above.
You can begin the risk assessment form via the “Start risk assessment” button on the Progress tab.
Complete the form by answering each question and providing a comment when prompted. The declaration at the end of the form will inform you whether the individual is considered normal or higher risk - based on the answers given.
6. Review risk assessment
Note: This step can only be completed by the fee earner.
The risk assessment review can be found on the Risk Assessment tab, you can either use the “Start review” to take you there, or move to the tab using the “Risk Assessment” button at the top.
The summary provides all the questions and answers given, any high risk answered questions are listed at the top. If the risk assessment needs to be amended for correctness, you can use the “View / Edit” button. Otherwise, use the “Complete” button if you agree with the answers and result of the risk assessment.
If the individual is considered to be of a normal risk, the AML is signed off following the completion of this step.
7. MLRO review
Note: This step is completed by the MLRO in the result of a higher risk individual.
The MLRO will review all the information and results provided. Following that, the MLRO will either decline or accept the sign off for the AML. In the case of declining, narrative is provided on the reasons and found on the Progress tab. If reasonable action is taken in line with the narrative, the individual can be re-submitted to the MLRO for a follow up review.
If the MLRO accepts the sign off, the AML process is considered complete.
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