If you are a Reporting Entity, AML legislation and guidelines require you to carry out OCDD on clients you have an ongoing relationship with, either because of a trigger event or after a period of time.
You can easily find clients whose CDD is due for a review using the OCDD Report. Your AML Programme may require you to visit 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.
2Shakes allows you to perform Ongoing Customer Due Diligence with a full review, update or re-do of existing Due Diligence.
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On this page you can find information on:
• Locating clients who are due for a review using the OCDD report
• Performing OCDD on clients
Finding client's CDD due for a review
AML Menu
OCDD Report
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 is 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:
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 would like to update or change the information, you can perform OCDD from the client management page.
Turn OCDD 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.
Performing OCDD
The OCDD flow retains historic IDVs and PEP check information. Plus, it analyses the previous IDV method, and either suggests an update in line with the latest guidance or keeps the previous IDV where it meets your needs. Whether you keep or re-do the IDV, you can still redo a PEP check as part of your OCDD.
Whether you use Sign Up with AML or AML Only, you can now:
- Re-run the client through the AML flow
- Add or remove beneficial owners
- See an updated Companies Office search with analysis
- Keep existing or re-do ID verification and PEP checks
- Update CDD information ready for reporting and auditing
- Build client CDD history, with full point in time due diligence snapshots
Getting Started
You can perform OCDD by kickstarting the CDD flow for an existing client, with all previous information available.
The OCDD function becomes available on the Client Management page once the initial client group has all IDVs completed, and the overall status is Complete.
Change in Beneficial Owners
You can add or remove beneficial owners and update CDD information, all from the AML Page.
With companies that are clients, 2Shakes automatically shows you previous beneficial owners against a current Companies Office search, and helps you find the right people to ID verify.
ID Verification and PEP Checks
For historic individuals within the client group, the page will display the method of ID verification used previously as well as suggests an update in line with the latest guidance material.
(Sign up with AML agreement)
Users can edit the IDV method for each historic person and decide whether to keep the existing ID and or re-do the PEP Check.
- If a new method of IDV is selected, the previous PEP check will not be kept, a new check will be included in the latest IDV.
- If keep IDV and re-do PEP is selected, the PEP check will automatically be completed as soon as the client is progresses from Draft to In Progress. The new PEP check will be reflected in the IDV report.
For individuals who have been newly added to the client group, they will appear under any historic people, and their IDV method can be selected as usual.
OCDD Cost
The cost of performing OCDD is already included in the small ongoing client charge with any paid plan. Even if you have multiple OCDD renewals for a client, you will still only be charged one Ongoing Records fee. As you’d expect, any additional electronic add-ons will be charged as usual.
Watch OCDD in action
For both AML only and Signup with AML
Watch the video below to see Ongoing Customer Due Diligence being performed in 2Shakes.
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