Anti-money laundering
Playbook
Draft 0.2.1Customer due diligence for real estate and precious-metals dealers
When a deal is created or changes in the client's ERP or CRM, identify the customer and its owners, screen them, check the deal against the reporting thresholds, hand anything that needs judgement to the MLRO, and file the evidence for the retention period. The agent prepares and records; people decide.
ComplyVerifyVault
What starts it
- In the client's system: deal created
- In the client's system: deal amount changed
- In the client's system: deal payment recorded
- On a schedule: rescreen existing customers
- When someone asks, e.g. “Screen this customer”
What the agent does
- Collect who the customer is
- Check the deal
- Screen
- Read the results
- Hand to the MLRO
- File the evidence
- Close the loop
What stays with a person
- Deciding whether a screening hit is a true match, a false positive or a partial match (Verify review screen; four-eyes if the client has it on)
- Opening, advancing or closing a partial-match suspension (PNMR) and any freeze
- Filing anything on goAML (STR, SAR, PNMR, REAR, DPMSR)
- Deciding to take on, continue or decline the customer
What it never does
- Clear or dismiss a screening hit, even when asked
- Tell the customer, or write in the client's ERP, anything about a suspicion (tipping off)
- Screen on a name alone when ID data is missing; ask for it instead
- Use a threshold, retention period or list rule from anywhere but an Arakan tool
Want to run this for your clients?
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