Ongoing Customer Due Diligence
You can now easily find clients whose CDD is due for a review. Your AML Programme may require you to revisit some clients and review CDD more frequently than other Clients. Once the initial CDD for a client is completed, the client will automatically be marked for ongoing CDD.
With the introduction of OCDD features, an AML menu has been added to the top navigation bar.
AML Statistics and AML Documents have also been relocated for easier access.
The OCDD Report will help you keep track of completed, customer due diligence. From one place, you can find clients who:
- have not had CDD reviewed for 3, 6, 12, 18 or 24+ months
as well as show clients who
- Have been identified as High Risk
- Required Enhanced Due Diligence
- Have not had an electronic PEP check done, or
- Have not been electronically IDV’ed
and any clients who
- Have entered passport details for eIDV and that passport has since expired
- Have been deselected for Ongoing Customer Due Diligence
Where any search criteria are true, the corresponding icons will be displayed for that client.
OCDD disabled clients will have a grey AML icon instead of black.
OCDD Report Example
NB. Coming soon – Companies Office change.
In the example above, the search is for clients whose CDD has not been reviewed for 3 months AND any clients whose passports have expired.
Even though the two clients’ CDD has been updated within 3 months, they show in the report because they have expired passports.
The OCDD report also tell us:
- Both clients have been electronically IDV’ed and had an electronic PEP check as no icons are displayed in the corresponding columns.
- John Smith has previously been flagged as High Risk, and Enhanced CDD was applied.
- Jane Smith has been deselected for OCDD as the AML icon is grey.
When selected, expired passports and OCDD not required will show in your search results regardless of the selected time frame. Search results show matches from the criteria group on the left AND any criteria selected on the right.
Reviewing Customer Due Diligence
From the OCDD page, you can click through to a client to review the most recent due diligence.
When you have reviewed CDD for a client and you are happy no further action is needed, you can record when OCCD has been completed by marking OCDD as done.
Whenever OCDD is marked as done, you will be prompted to record when the review occurred. A note will be committed to Notes & Files recording OCDD as done, the automated note can also be edited.
Remember, it is important to note any change in your client’s business activities when revisiting CDD.
Turn OCCD Off
OCDD for a Client can be switched off and on at any time. Use the Disable Ongoing CDD feature to show you don’t need to carry out Ongoing Due Diligence for this customer. For example, you don’t have an ongoing business relationship with them because they were a one-off transaction or they are no longer a customer.
If you choose to disable OCDD, a note will also be committed to Notes & Files recording OCDD was turned off for that client. Clients that have OCDD disabled will have a grey AML icon when they appear in the OCDD report.