01Key Responsibilities
1. Collection and Verification of Documentation
Initial Documentation Request: Communicate directly the dedicate client facing function to request all required AML/KYC documents, specifying the exact type and format acceptable (e.g. certified true copy, translation requirements, apostille as needed).
Document Review: Examine and validate identification documents (passports, national IDs, corporate registration, beneficial ownership structures, proof of address, source of wealth/source of funds evidence) for completeness, authenticity, and alignment with declared information.
Beneficial Ownership Analysis: Identify, document, and verify all ultimate beneficial owners (UBOs), controllers, and significant persons associated with the client/investor, in line with the latest regulatory thresholds and definitions.
Tax and Regulatory Classification: Collect and record information for FATCA, CRS, ensuring proper classification (US person, reportable account, direct investment versus intermediary etc.) and obtain self-certifications where required.
2. In-depth AML Risk Assessment Application of Risk Scoring Models: Assess AML risk based on the client's jurisdiction, entity type, ownership structure, product type, distribution channel, and the nature of expected transactions. Risk Factors Evaluation: Thoroughly consider standard and enhanced risk factors such as:
Politically Exposed Person (PEP) involvement
Business/sector risk (e.g., cash-intensive businesses, trust/charity structures)
Geographical (country of residence/incorporation) risk ratings high, standard, or low, referencing the most recent risk maps and regulatory guidance
Complex ownership/asset structures or use of intermediaries
Unusual or opaque sources of wealth or funding Risk Rating Assignment: Assign an overall risk score (e.g., Low/Medium/High) in accordance with defined guidelines. Clearly document the justification for each risk rating step.
3. Name Screening and Negative Media Checks KYC Screening: Conduct KYC name screening for all relevant parties (client/investor, UBOs, directors, signatories) against:
Sanctions lists (OFAC, EU, UN, HMT, etc.) PEP databases
Adverse media/news (e.g. World-Check, Dow Jones) Handling:
Log all screening hits and determine genuine matches versus false positives using robust procedures.
Investigate potential matches, assess risk implications, and escalate genuine hits to Senior Analysts or Team Leaders per escalation matrix.
Document all screening findings and investigations, ensuring clarity and auditability. For more guidance, please refer to the section Screening Investigation and Documentation at the end of this document.
4. Due Diligence Level Application & Enhanced Due Diligence Activities Determine Due Diligence Level: Apply the correct level of due diligence (Standard or Enhanced) as determined by the risk assessment.
For Standard Due Diligence: Satisfy baseline identification and verification steps and review for basic red flags.
For Enhanced Due Diligence (EDD): Conduct additional verification steps which may include:
Seeking independent or corroborative evidence of source of wealth/funds
Gathering additional documentation for high-risk countries or complex structures
Conducting web-screening for reputational risk
Liaising with compliance for approval prior to onboarding/investment approval Ongoing Monitoring: Participate in periodic reviews, event-driven reviews (triggers such as change in ownership, negative news, new PEP status), and transaction monitoring reviews as instructed.
5. Record Keeping, System Updates and Reporting Data Entry: Ensure accurate and timely updates to due diligence data in KYC and investor registry systems; maintain detailed and logically organised electronic files and audit trails.
Reporting: Prepare internal checklists, due diligence summaries with explanatory narrative on the due diligence performed (e.g.: risk driver, red flag), and escalate files requiring review in a clear, fully documented manner.
6. Communication and Support Investor and Counterparty Queries: Efficiently handle inbound and outbound communications (phone, email, conference calls) related to document requests, clarification of AML requirements, regulatory queries, and case status updates. Collaboration: Work closely with Senior Analysts, Team Leaders, Compliance, and other internal stakeholders to resolve open points and ensure seamless onboarding or review.
7. Compliance and
