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regulated sector, Wealth Management is becoming increasingly vulnerable to the
risks of financial crime. It is therefore crucial that the sector ensures that
it’s compliance and anti-money laundering (AML) checks are watertight or face
heavy fines and exposure to fraud.
To stay compliant,
it is vital that Wealth Management firms perform thorough anti-money laundering
checks on all clients, ensuring that they really know their customers and
remain vigilant to certain behaviours and irregularities resulting in a safer
industry from both a social and financial crime perspective.
latest blog, AML and Wealth Management expert Michael Shaw explores the
importance of establishing a robust AML and KYC programme and the role that
monitoring customers has to play.
it comes to putting a comprehensive, robust and reliable anti-money laundering
programme in place, customer due diligence - verification checks and screening
- are absolutely vital.
part of their required customer due diligence, regulated business in the UK
need to verify every customer they work with to ascertain three things:
1. If the person is
2. If the
identification (ID) documents they are providing are legitimate
3. If the individual
and the ID documents match
an individual has been verified, they then need to be screened against
Politically Exposed Person (PEP) and sanctions lists to ascertain the level of
risk - if any - doing business with that person poses to the business.
this process has been completed, and the checks have shown the person to pose no
risk, the business can go ahead and onboard that customer.
this is just the first part of the process; due diligence obligations do not
end there. For regulated firms to fully meet their legal AML obligations, they
must also have a comprehensive customer monitoring system in place.
means that to remain compliant, the business must regularly check their
customer database for any changes that could impact the risk posed to the
business, for example, a customer becomes more vulnerable to bribery - either
as a PEP themselves, or someone who is closely associated with a PEP, known as
RCAs (Relatives and Close Associates), or they become a SIP (Special Interest
Person) as a result of being convicted - or arrested or on trial - for a
financial or serious crime.
monitoring of customers and their status can be difficult for businesses to
manage - especially when they are still relying on manual AML checks. Not only
because it is hard to keep on top of, but it is also difficult not to get
bogged down by false positives.
easiest way to keep on top of regular customer monitoring, and reduce false
positives, is to use an automatic global PEP and sanctions checking service.
technology is able to screen an entire customer database every night against
global Watchlists, which includes information about PEPs, RCAs, SIPs and
sanctions information, that is updated continually. Each customer on the
database can be screened against these lists, so if a customer is identified as
a PEP, or other high-risk person, or has sanctions against them. Furthermore,
the technology can run enhanced due diligence on any matches to remove false
positives and reduce any unnecessary action.
Martin Cheek, Managing Director of SmartSearch - a leading AML
platform with automatic screening and monitoring, said: “It is virtually impossible to run proper customer monitoring using
manual processes. Not only is it incredibly time-consuming, but there are so
many different resources that it is unfeasible for a firm to be checking every
single one regularly enough for the monitoring to be a true indication of risk.
“The only way that regulated firms can be sure that they are
meeting their customer monitoring obligations is to automate. Our ongoing monitoring service
is supported by the Dow Jones Factiva Watchlist which comprises of more than
1,100 worldwide Sanction and PEP lists. Our system takes updates from the list
every night and our efficient and innovative data matching processes work to
greatly minimize the number of false positives returned so that our customers
are only alerted when a true match is made.”
Enterprise Business Development Manager