Completing an AML Check
Finley makes it easy to record your client identification and Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) checks directly against the client record.
The Identity Check workflow captures both the client's identification details and your AML/CTF risk assessment, providing a clear record of the checks completed.
Step 1: Create New Identity Check
From the client record in Finley:
Select Identity Check from the left-hand menu.
Click the + button in the top-right corner.
Finley will open the Create Identity Check workflow.
Step 2: Complete Identity Details
Select the relevant client or entity under Owner, then record the identification information used to verify their identity.
Depending on the identification document and verification process, this may include:
Verified From – for example, Driver Licence.
Verification Method – for example, Original Sighted.
Country of Residence.
Name on Document.
Date of Birth.
Place of Residence.
Expiry Date of the identification document.
Card or Document Number (last 3 digits only).
Verified Date.
Verified By.
The information entered should accurately reflect the identification document sighted or the verification process undertaken.
Once the identity details have been completed, select Next to proceed to the AML/CTF risk assessment.
Step 3: Risk Assessment
The second stage is the Risk Assessment.
Finley presents a series of questions designed to help you assess the AML/CTF risk associated with the client and the relationship.
The assessment considers matters such as whether:
You are reasonably satisfied that the client is who they claim to be.
The person you are dealing with matches the identification information provided.
Any structures or entities involved are not designed to conceal the identity of beneficial owners.
The beneficial owners have been identified where relevant.
The client is not a high-risk Politically Exposed Person (PEP) or an associate of a high-risk PEP.
The client is not based in, or conducting business through, a high-risk foreign jurisdiction.
There are any other circumstances that may increase the client's AML/CTF risk.
Answer each question based on the information available and the enquiries you have undertaken.
Where Finley provides an N/A option, this should only be selected where the particular question genuinely does not apply to the client or entity being assessed.
Enhanced Due Diligience
If you answered No to any of the risk assessment question, the customer is considered high risk and Enhanced Customer Due Diligence should be completed and documented.
Consider the Overall Risk
The risk assessment should not be treated simply as a checklist. Consider whether any response indicates a heightened AML/CTF risk requiring further investigation or additional identification and verification procedures.
For example, additional enquiries may be appropriate where:
The client has a complex ownership structure.
The beneficial ownership arrangements are unclear.
The client or beneficial owner is a PEP.
The client has connections with a higher-risk foreign jurisdiction.
The source of funds or source of wealth requires further clarification.
The circumstances of the client relationship are unusual or inconsistent with the information provided.
Any additional enquiries or supporting information should be appropriately documented on the client file.
Completing the Check
Once all risk assessment questions have been reviewed and answered, select Create.
Finley will save the completed Identity Check against the client record, providing a record of:
the identification information collected;
how the client's identity was verified;
when the verification occurred;
who completed the verification; and
the AML/CTF risk assessment undertaken.
The completed check can then be referred to as part of the client's ongoing compliance record.
Remember
Completing the Identity Check in Finley is intended to document the AML/CTF customer identification and risk assessment process. Advisers should ensure that the information recorded reflects the checks actually undertaken and that any higher-risk circumstances are appropriately investigated and documented.
Where client circumstances change, or new information becomes available that may affect the client's AML/CTF risk profile, the client's identification and risk assessment should be reviewed and updated where appropriate.