Compliance as a Service: Managed Client Onboarding & Monitoring
Assuming the ever-increasing number of regulatory obligations and tasks related to compliance, at some point it might become financially burdening to maintain a big enough compliance department within a company. When it happens consider that outsourcing might become a valid alternative to save money without losing quality of work and exposing the business to risks. For our clients who decided to outsource their compliance function, we offer a variety of compliance services which can be provided in any combination depending on your situation. These compliance services include:
Before you enter into a business relationship, you need to check your customer’s identity and do what is possible to ensure that this identity is not false. We can do that for you by checking your customer’s documents in special databases which include information about lost and stolen IDs, controlling their authenticity through protection marks, and by performing a thorough scan of personal information to see if there is a sign of discrepancy or misinformation. Then we arrange verification of the identity – which is a confirmation that the documents match the individual. It can be conducted in person or remotely – i.e. we contact your client and meet them, or perform verification through our authorized representatives in other regions, or arrange such verification by digital means of telecommunication.
Even if the customer’s identity is true and valid, there are still risks which must be identified, analysed and taken into account before accepting. They include AML/CTF risks, sanctions risks, type of operation, source and destination of funds, and many others. The result of the analysis is the conclusion of the compliance officer upon assigning a risk level to the customer, and an advice on acceptance or non-acceptance of that customer. As compliance professionals we have the skill and knowledge to perform this task in a time- and cost-efficient manner without damage to the quality of work.
It is not enough to only perform due diligence and acceptance procedures, you also need to compose a full dossier, which will contain all the required information and documents, so that in case of an audit or any other kind of supervisory check you would be able to support your assessment of the customer’s risks, decision on the acceptance etc. with documentation. Such dossiers must be regularly reviewed to ensure that the information is correct and up-to-date.
The transaction profile is what you know and expect of the customer’s (future) activities and transactions. This is the most essential information for conducting an appropriate analysis of financial and AML/CTF risks.
If you receive information about the customer’s financial transactions, it is your duty to monitor them in order to identify a possibility of money laundering or terrorist financing. It includes checking the counterparty, and ensuring that there is an economic and legal substantiation of those transactions.
Non-financial transactions (legal transactions) should also be checked at least to the extent of counterparty check towards criminal activities and sanctions.
When monitoring of transactions results in a suspicion of money laundering, terrorist financing or just shows an unusual transaction for this customer’s normal profile, it can be your obligation by law to immediately report such transaction to the authorities – a local branch of the Financial Intelligence Unit (FIU) and/or regulator of the financial sector. We will be happy to perform this reporting duty for you. Ideally, this service should go along with the transaction monitoring service to remove the communication disruption risk.
Know your customer and customer due diligence are conducted in order to determine possible risks about the customer you wish to take on board in order to understand if they fall within the risk appetite of your business. It contains a deep background check and research on source of funds, volume of business, counterparties of such customer etc. Despite being a very common, even mundane task for nearly every enterprise, it should not be taken lightly – in the worst case scenario a negligently performed KYC/CDD might cost your business very much, not only in direct losses but also in reputation loss.
Some categories of companies and institutions are obliged to perform a risk assessment of their business, policies and procedures, beneficiaries, stakeholders, clients and so forth in order to foresee potential problems and developing prevention and mitigation measures. SIRA stands for Systematic Integrity Risk Analysis and serves as an important tool for the management of a company as well as for supervising authorities to understand the strengths and weaknesses of a business.
Customers or counterparties who meet one or more certain indicators (e.g. CPI index of country of origin) might be required to be subjected to a higher degree of scrutiny by law.
To ensure the integrity of your counterparties, partners and employees you can use our service of screening, which includes background checks, database checks, controlling authenticity of certificates and diploma’s, checking references and contacting referees. Furthermore, we conduct searches in public and non-public sources.
By requesting External Compliance Officer services you get the possibility to use the skills and knowledge of a compliance professional for tasks and questions which arise around the compliance function in your business.