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1. 1

   KYC and KYB form

   Knowing starts with asking. An online form for individuals and for companies, with the fields required by the regime that applies to each.

2. 2

   Data and document record

   Supporting documents, data processing authorisation and source of funds declaration, stored with their date and with who received them.

3. 3

   Screening and due diligenceHere

   Binding and sanctions lists, PEP, judicial and disciplinary records and adverse media. Enhanced due diligence when the risk calls for it.

4. 4

   Segmentation by risk factor

   Counterparty, product, channel and jurisdiction. This is what sets how deep the next review goes and how often it has to happen.

5. 5

   Recurring collaborative monitoring

   A counterparty is not screened once. Periodic revalidation and notice when a match appears that was not there before.

6. 6

   Data refresh

   Segmented by external risk factor, in three modes: external, when the source changes; operational, when something in the relationship changes; and recurring, by calendar. The data goes back into the file and the cycle starts again.

And it starts again: the refresh returns to step 1 for as long as the relationship lasts.

When a stage raises a flag

• ML/TF/PF · corruption alerts

  The flag can surface in screening, in segmentation or in monitoring. Wherever it is raised, it is recorded with its evidence, its date and the criterion behind it.

• STR

  The suspicious operation report to the financial intelligence unit is decided and filed by the compliance officer. The platform gathers the evidence to support it.

Running the cycle sustains a prevention system; it does not replace the compliance officer’s judgement or their reporting decisions.