I. CUSTOMER IDENTIFICATION AND VERIFICATION 20%
1.1 Assess the information needed by determining
customer type, then research sources as needed to
complete gaps
1.2 Complete appropriate verification procedures
1.3 Assess nature and purpose of the account, with
particular attention to shell companies and tax
compliance
1.4 Identify ultimate beneficial ownership (UBO) and
connected/third parties
1.5 Review and re-consider existing information based
on account activity II. CUSTOMER SCREENING 15%
2.1 Screen for sanctions compliance
2.2 Explore primary and secondary sources for customer
information (including adverse media) and assess
reliability and relevance of information
2.3 Distinguish between material and immaterial hits
coming from sanctions checks and transaction
monitoring, then validate as appropriate. III. CUSTOMER RISK RATING 20%
3.1 Evaluate customer risk based on core risk categories
(customer, product, country, channel)
3.2 Recognize and explain key red flags that could
signal money laundering, sanctions evasion, bribery/
corruption, tax evasion, etc.
3.3 Analyze risk of assets under management
3.4 Assess risk scoring against company risk
assessment/risk appetite and escalation
requirements. IV. ENHANCED DUE DILIGENCE 30% 4.1 Identify and obtain details of source of wealth
4.2 Examine complex ownership structures for ultimate
beneficial ownership (UBO)
4.3 Determine based on evidence of risk level whether
to recommend retaining, terminating customer, or
escalating for further enhanced due diligence (EDD)
4.4 Perform account activity reviews. V. CUSTOMER PROFILE DOCUMENTATION AND PRESENTATION 15%
5.1 Apply data privacy requirements and explain
ramification of data errors
5.2 Present effectively crafted profiles with objectivity
and precision
5.3 Create an audit trail
5.4 Review/update customer profile based on periodic
review or event triggers.