AML/CFT and CDD Requirements

  • Updated

What is Customer Due Diligence?

Customer Due Diligence (CDD), is the process where relevant information about the customer is collected from documents, data, or information obtained from reliable and independent sources, in order  to verify identities. This is then evaluated for any potential risk for the organisation including any money laundering/terrorist financing activities.

The Company Compliance screen will help you in complying with the Anti-Money Laundering (AML)/Countering Financing of Terrorism (CFT) and Client Due Diligence (CDD) requirements for your Company.

From the Main Toolbar, go to Company mceclip1.png
Select the Company from the list mceclip0.png
Select Compliance

If Compliance & Due Diligence is expected but not immediately required, toggle OFF Compliance & Due Diligence Required?

Enter the Next Review Date and any Notes as a reviewer. 

Once you are ready to proceed, toggle ON Compliance & Due Diligence Required? This will open further steps (see below)

ClickScreen_Shot_2020-11-17_at_4.22.55_pm.pngand Screen_Shot_2020-11-17_at_4.22.36_pm.png to navigate through the sections.

You can always save your progress by clicking Screen_Shot_2020-11-17_at_4.22.44_pm.png
You can also print off the Compliance Report by clicking

Steps

1. CDD Required
Start Date The date you will be starting the CDD process for the entity.
Completed Date The date you completed the CDD process for the entity .
Compliance Officer Begin typing the Compliance Officer name. CAS 360 will begin searching the Global Contact screen. If the contact has not been previously saved to the database, select mceclip3.pngto create the contact.
Upload Supporting Documents Upload any supporting documents appropriate for the CDD process for the entity.
2. Nature of Business Relationship
Nature of Business Relationship

Select from the range of options regarding your business relationship with the customer.

Select Free Text to enter a relationship that is not listed in the range of options. 

If required, click Screen_Shot_2020-11-17_at_4.02.00_pm.png if multiple relationships exist.
3. Individuals

The individuals section will list all Members and Officers of the entity.

Next to each individual, you will be able to instantly identify the individual's shareholding percentage.

Hover your cursor over the information icon 9.png. Users will be able to instantly see the individual's general details. 

To edit any of these details, select Screen_Shot_2020-06-25_at_12.54.27_pm.png

Question: Compliance & Due Diligence Required? 

Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if Compliance and Due Diligence is believed to be required for the indivdual. This will then allow you to upload supporting documentation for the individual.

PEP Check Required? Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if a politically exposed person check is required

Source of Funds Required? Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if information on the person's source of funds in the establishment of the business relationship is required. 

Select +Additional Contact to list additional individuals

4. Ultimate Beneficial Owners

The Ultimate Beneficial Owners section will list all Ultimate Beneficial Owners.

“Beneficial owner” in relation to a customer means:

  • An individual who ultimately owns or controls (whether through direct or indirect ownership or control) more than 25% of the shares or voting rights of the customer; or;
  • Otherwise exercises control over the management of the customer. 

Hover your cursor over the information icon 9.png. Users will be able to instantly see the individual's general details. 

To edit any of these details, select Screen_Shot_2020-06-25_at_12.54.27_pm.png

Question: Compliance & Due Diligence Required? 

Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if Compliance and Due Diligence is believed to be required for the individual. This will then allow you to upload supporting documentation for the individual.

PEP Check Required? Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if a politically exposed person check is required

Source of Funds Required? Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if information on the person's source of funds in the establishment of the business relationship is required. 
Provide information on the nature of beneficial ownership (e.g. more than 25% of ownership of the company) or person having executive authority 
Information on ownership and control structure of, or over the customer/client. 

Select +Additional Contact to list additional Ultimate Beneficial Owners. 

5. Business Entities 

The Business Entities section will list all shareholders that are companies.

Next to each entity, you will be able to instantly identify the entity's shareholding percentage.

Hover your cursor over the information icon 9.png. Users will be able to instantly see the entity's general details. 

To edit any of these details, select Screen_Shot_2020-06-25_at_12.54.27_pm.png

Question: Compliance & Due Diligence Required? 

Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if Compliance and Due Diligence is believed to be required for the entity. This will then allow you to upload supporting documentation for the individual.

PEP Check Required? Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if a politically exposed person check is required

Source of Funds Required? Toggle Screen_Shot_2020-11-17_at_3.48.43_pm.png if information on the entity's source of funds in the establishment of the business relationship is required. 

Select +Additional Contact to list additional companies and/or other entities. 

6. Risk Assessment
Select Risk Option

Select from a range of different Risk Factors. Click Screen_Shot_2020-11-17_at_4.12.38_pm.pngto add multiple risk factors.

Once a Risk factor has been selected, CAS 360 will make available a free text section for you to be able to add any further information.

Screenshot 2024-02-29 at 9.29.20 am.png

Any supporting documents can also be attached to a risk option

Note: Both text box and Supporting documents are not mandatory fields.

Question: Having reviewed the above risk areas, the overall risk rating for the client is.

 Rate the client risk level

 

Simplified customer due diligence

This can be applied when a risk assessment has the client has a tolerable risk rating. The only requirement is to identify the customer and there is no need to verify the customer’s identity.

Enhanced customer due diligence

Enhanced CDD must be applied when the risk rating for the client is deemed to be intolerable. This will thus require extensive CDD over the client. An example of such an individual is if the person in question is a politically exposed person.

Standard customer due diligence

A Standard level of CDD can be applied when the risk rating for the client is not appropriate for either the Simplified or Enhanced levels of CDD.
7. Notes

Additional findings arising throughout the course of the AML/CDD workflow can be recorded here.

To begin recording additional findings, click Screen_Shot_2022-12-06_at_10.18.33_am.png

CAS 360 will display the Add Note window.

Each note can have a title and the note content. CAS 360 will also display a time stamp to show when the note was last modified.

Notes can be deleted by selecting Screen_Shot_2022-12-06_at_10.24.29_am.png beside the note.

Click Screen_Shot_2022-12-06_at_10.22.49_am.png to add any additional notes.

Click Screen_Shot_2022-12-06_at_10.22.42_am.png to save the note.

8. Risk Review
Completed By Select, from a list of your CAS 360 users, the user completing this CDD process
Date Completed Date the CDD process has been completed
Next Review Required Date the next CDD process will be required

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