filtered out by threshold
Low-value orders fall under the rule and are never reviewed, even when together they form a pattern.
Every client, trade and change sits in one record, rated the same way for every relationship.
Most firms switch on the full process from day one. Since onboarding, screening, risk scoring and transaction monitoring all feed information into the same client record, continuous monitoring is always able to obtain a full view.
It is almost never in question whether a client was checked during onboarding; the issue instead being whether that check is still valid today and whether the firm can demonstrate that it has applied the same standard to every client. This is only the case when monitoring is continuous and the evidence is kept in a single location.
Low-value orders fall under the rule and are never reviewed, even when together they form a pattern.
A new entry on the sanctions list, an appointment to a PEP position, or an adverse media story can remain unseen for months.
It is assigned during onboarding by judgment, and it becomes difficult to explain to a supervisor a year later.
People, companies and fund layers are verified and resolved to the natural persons who own or control them. Step 03: Every transaction is monitored from the first unit, and changes to the risk score apply immediately.
For all clients the screening results, ownership, geography, products and behavior are evaluated using the same model, and enhanced due diligence is carried out where the score so requires it.
The transactions monitored from the first unit and any change to the client's risk score are immediately reflected.
The file lists everything that was known, together with the time at which it was known, the score that applied and the person who accepted it.
The rules vary from market to market, but the expectation is uniform in all cases: you must know the client, keep a close watch on the situation, and make it clear that each decision was taken using the same method. The record has to include evidence to prove this.
Read the compliance guidesReviews restarted from scratch because the previous decision left nothing behind. Once the trail carried forward, the cycle became a check on what changed rather than a re-reading of the file.
To the natural persons who own or control the client, across registry sources, with each hop recorded and dated. Wealth structures often pass through several layers before reaching a person, and the file shows where each link came from and when it was verified.
Yes. Holding companies, trusts and fund layers are resolved down to the people who own or control them. For a trust, that means the settlor, trustees, protectors and beneficiaries, since each can hold control without holding any shares.
Screening results, ownership, geography, products and behaviour are assessed with the same model for every client. Consistency is the point: a supervisor asks less whether a client was checked than whether the same standard was applied to all of them.
Where the risk score requires it, including documented EDD for foreign PEPs. The case opens with the factors that pushed the score over the line, so the reviewer starts from the reason, not from a blank form. Source of wealth and source of funds are collected on the same record.
On the client record with its supporting documents, not in an onboarding mailbox or a relationship manager's inbox. When the client adds new assets years later, the new explanation is read against what was recorded at onboarding.
Yes. Transactions are monitored from the first unit, so low-value orders that form a pattern are not filtered out by a threshold. Layering through investment accounts rarely looks large on a single trade; it shows up in frequency, timing and the accounts the money moves between.
Yes. PEP scope includes relatives and close associates across four tiers, so a family member or business partner of a public official is flagged even when their own name carries no exposure. In private wealth, this is often where the exposure actually sits.
Yes. A review opens pre-populated with the last decision and highlights only what has changed since. The reviewer confirms the unchanged parts and spends time on the new ones, which reduces review effort without reducing what is checked.
For as long as your jurisdiction requires, configurable per regime and retrievable per client for the full period. Five years after the relationship ends is the common baseline, and some regimes and firm policies extend it to ten. Each record stays readable, not just archived.
Everything that was known, when it was known, the score that applied and who accepted it. The file answers the question supervisors actually ask: whether a decision made years ago was reasonable on the information available at the time.
We will resolve it to natural persons in the demo, and show you what the file looks like a year later.