An AML risk assessment is a complex and intensive task, but nonetheless a very necessary one. The periodicity of the assessment will depend upon a number of factors including an appropriate frequency to investigate existing clients according to their risk classification and at times when the relevant circumstances of a client has been changed.
With the 5th AML directive on its way, which needs to be transposed to national legislation before January 10th 2020, you need to verify your client data with ‘a reliable and independent source and where available electronic identification means.’
The screening of Politically Exposed Persons (PEP) and the Ultimate Beneficial Owners (UBO) requires a significant amount of attention, especially because these data are not static. A person’s involvement into politics can be very temporarily nowadays and the ownership of a company is not a static element, like a date or place of birth.
The use of external public data providers, in order to check against PEP or UBO data, is already widely known and intensively used. But the time spent controlling the outcomes, containing false positives, has increased enormously. If your periodic reviews are embedded in an automated workstream and the queries to data providers are as precise as possible, you only need to intervene if a true red flag is raised. All the other results of your periodic review are recorded in your client’s audit trail, on individual and on corporate level. Harmoney delivers this workflow, so your time spent on periodic reviews was an efficient one!