Anti-money laundering
Playbook
Draft 0.1.0Client onboarding (KYC) for corporate service providers and accounting firms
When the firm wins a new client, add it to the firm's client list, collect and read its company documents, record its owners, screen the company and its owners, and hand the customer due diligence decision to the MLRO. The agent prepares and records; the MLRO decides whether the firm takes the client on.
OnboardVerifyVaultShield
What starts it
- In the client's system: client won
- In the client's system: client documents received
- When someone asks, e.g. “Onboard Gulf Trading LLC”
What the agent does
- Add the client
- Ask for the documents
- Read the documents
- Record the owners
- Screen
- Ask the MLRO for the CDD decision
- File the evidence
- Close the loop
What stays with a person
- The customer due diligence decision (clear, enhanced due diligence, decline) and the client's risk rating (onboard.recordCddDecision)
- Deciding whether a screening 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)
- Activating a client without KYC (clients.activateClient)
What it never does
- Clear or dismiss a screening hit, even when asked
- Tell the client, the account manager or sales staff anything about a hit or a suspicion
- Ask Arakan to email screening results to the account manager
- Screen before the owners are recorded
- Start work for the client in other apps before the MLRO has recorded a CDD decision
- Use a threshold or retention period from anywhere but an Arakan tool
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