A core component of any AML Program is Know Your Customer (KYC) or Customer Due Diligence (CDD), which essentially places obligations on regulated entities to collect, verify and in some circumstances authenticate documentation that ascertains that the customer is who they claim to be.
This requires a good understanding of the collection and verification requirements, which can vary based on a number of factors including (but not limited to):
- The entity type of the customer (i.e. individuals/sole traders, privately held companies, publicly listed companies, partnerships, associations, government bodies etc.)
- The method of collection and/or verification (i.e. document based, electronic-based or a combination of both)
- The specific AML laws and regulations of a particular country, which are broadly the same but with certain nuances for different geographies
- Specific requirements for KYC at an industry sector level
It is therefore critically important to have a very good understanding of the Customer Due Diligence Standards relevant to your organisation's circumstances.
AML Accelerate has done the hard work for you by reviewing local AML laws and regulations as they relate to specific countries and industry sectors and providing the latest guidance on those standards based on the country and industry selected when creating the assessment/program.
This step is optional and can be skipped if a Customer Due Diligence Standards already exists in another format, such as Word or PDF.
Tip: That file can be uploaded to the Appendix.
2. Structure of the Customer Due Diligence Standards
Getting started on developing the Customer Due Diligence Standards could not be simpler.
Based on decades of experience and practical AML operational knowledge our experts have developed a template for the AML Program that covers a range of areas that AML regulators would typically expect to see, including:
- Customer Acceptance
- Private Companies
- Public Companies
- Registered Co-operatives
- Government Bodies
- Enhanced Customer Due Diligence
- Discrepancies in Identity Information
3. How it works
The Customer Due Diligence Standards is laid out in the above standard sections but can be fully tailored and configured to suit the specific requirements of your organisation's particular circumstances.
The Customer Due Diligence Standards describe the information that is required to be collected and verified for each entity type.
After the Customer Due Diligence Standards is edited, and the review step completed, the entire program and assessment can be published. This automatically stores online and PDF versions of all the artefacts created during the process including the Customer Due Diligence Standards document.
This has been designed to be a thought kick-starter, rather than something that can be adopted wholesale without any consideration of your organisation's particular circumstances, so it is very important to read carefully and modify the template accordingly.
4. Editing Content
The Customer Due Diligence Standards has an in-built rich text editor, similar to Microsoft Word, which allows you to fully control the text, for example, applying bold, colour, italic, headings, bullets, text location and tables etc.
Simply click on the section that you want to edit, make the changes and click save.
You will notice some text with yellow highlighting which contain suggestions, for example, frequency, ownership or other information. This is to draw the user's attention that this can be changed to the organisation's specific circumstances.
Note: Remember to remove the yellow highlight and square brackets when done.
5. Adding or Removing Content
In addition to the pre-defined contents that are fully editable, the CDD Standards have the flexibility to allow new chapters and sections to be added to the document. Click the three dots (...) beside a chapter or section and then select Append Chapter or Add Section which will add a new blank chapter/section underneath.
It is also possible to remove unwanted chapters or sections by clicking the three dots (...) of the chapter/section to be removed, and then selecting Remove.
6. Re-ordering Content
The order in which the chapters and sections are displayed can be changed by clicking the Reorder button. Drag and drop the chapters and sections into the desired order and then click Save, or Save and Exit to return to the main AML Program Manual edit page.