Anti-money laundering
Playbook
Draft 0.1.0Ongoing re-screening of existing customers
Screen the client's existing customers again on a schedule and when a customer's details change, compare each result with the last screening, and send only what changed to the MLRO. Unchanged results are filed as evidence; nothing is decided by the agent.
VerifyVault
What starts it
- On a schedule: rescreen active customers
- In the client's system: customer identity changed
- In Arakan: sanctions lists updated
- When someone asks, e.g. “Re-screen all active customers now”
What the agent does
- Which customers
- How to re-screen
- When something changed
- When nothing changed
- After each run
- When a customer's details change
What stays with a person
- Deciding whether a new or changed hit is a true match, a false positive or a partial match
- Opening, advancing or closing a partial-match suspension (PNMR) and any freeze
- Filing anything on goAML (STR, SAR, PNMR)
- Deciding to continue, restrict or end the business relationship
What it never does
- Clear or dismiss a screening hit, even when asked
- Tell the customer, sales staff or the client's systems anything about a hit or a suspicion
- Count a screening that did not run as clear
- Re-screen a customer whose relationship has ended, unless the MLRO asks
- Use a list rule or retention period from anywhere but an Arakan tool
Want to run this for your clients?
Partners get the full playbook: the agent's instructions, the client settings, the connections it needs and its test scenarios.