Peak AML Compliance for PEPs, Affiliations
PEPs and other affiliations can be a nightmare in AML due diligence across the span of a customer lifecycle—they can present high risk but are tough to track and organize efficiently and effectively—especially if you’re stuck with manila folders or stovepiped tech tools. That’s why we build multiple seamless tracking and screening features for PEPs and other affiliations into our AML software ecosystem—a single seamless end-to-end AML software solution based on Ecosystem Thinking.
Consider, for a moment, the still-unfolding Petrobras scandal in Brazil. The Wall Street Journal reported this week that Brazil’s Supreme Court “has ordered investigations into one-third of the country’s sitting ministers and scores of top politicians for alleged corruption.” Stories of suitcases full of cash and a massive bribery network involving numerous politically-exposed persons have been under investigation for several years now.
For AML Compliance professionals, these kinds of stories highlight not only the risk of PEPs and various other affiliations but also the challenges given the international nature of commerce, shell companies, ultimate beneficial owners, and the global flow of money. Smart software design of AML Compliance solutions can greatly mitigate this risk.
We at AML Partners continually leverage our AML expertise with our software-design innovations. For PEPs and other important affiliations, we analyzed the problems they present to AML Compliance, and we created the following Ecosystem solutions:
AML Problem: During on-boarding, it’s often a struggle to use disconnected processes to assign associated individuals to customer accounts. Each account may have UBOs, PEPs, a board of directors, senior managers, co-owners—and any other designation that might apply. It’s a never-ending time suck to collect and enter this information accurately and completely over and over and over for multiple customers, many of whom share associated individuals and/or entities.
AML Ecosystem Solution: Identify your PEPs and all other associations during the CDD on-boarding process and enter those associations into our AML ecosystem’s Principles Registry only one time. Then simply assign the association—entered that single time—to any and all customer records that require that association. And when you assign an association saved in the Registry to a customer account, you select the appropriate designation—whether that is as a PEP or as another designation determined by you. Imagine that: PEPs or other associations entered once and available for linking to as many customer records as needed—that is smart AML in an ecosystem solution.
AML Problem: Screening and rescreening take a lot of time, organization, and attention to detail long after the on-boarding due diligence has been completed. And sometimes PEPs and other affiliations slip through the cracks.
AML Ecosystem Solution: AML Partners’ ecosystem AML solution includes automated screening and rescreening throughout the AML ecosystem—in multiple locations—to ensure that PEPs and other affiliations are determined and highlighted even after the account is opened and operating. In the AML ecosystem, rescreening can happen at any interval against any list—it’s simply a matter of in-house configuration.
AML Problem: The transaction-monitoring phase of a relationship raises all kinds of new problems related to unknown parties—some of whom may be PEPs—that appear when cases are created. During the ongoing due-diligence monitoring, behaviors may trigger that result in cases created with multiple transactions within the case. Most of these parties will not be your customers and you will have no information on them, other than sanctions screening, which should already have occurred. An institution cannot legally conduct business without knowing who these people are.
AML Ecosystem Solution: SURETY Eco screens all persons on every transaction that creates a research case, which is created when a behavior is triggered. Once a behavior has triggered, SURETY Eco’s Behavioral Monitoring tools automatically screen the originator, all the intermediaries, and the beneficiaries of every transaction that resulted in the behavior being triggered. And SURETY Eco automatically screens against sanctions lists and adverse media as soon as a case is created, so those bases are entirely covered as well.
AML Problem: Institutions that take on high-risk books of business have heightened screening needs—for PEPs, other affiliations, sanctions, and transactions. Stakes—and risks—are especially high, and staying on top of screening consumes major amounts of time and money.
AML Ecosystem Solution: SURETY Eco includes automated nightly screening with full de-duplication, features that are especially useful to institutions with high-risk books of business. Screen all of your high-risk customers on an ongoing basis—in a manner precisely configured by each institution according to its unique Risk-based Approach.
With Ecosystem Thinking, the identification of PEPs and other affiliations becomes an integrated part of the end-to-end solution for effective and efficient AML Compliance. With an AML software ecosystem, effectiveness and efficiency drive the process from the start of on-boarding to the end of the customer account.
SURETY Eco–The AML Compliance Ecosystem for Peak Performance and Configurability
AML Compliance benefits tremendously from systems thinking, specifically AML ecosystems. If you’re ready to explore the power of the software ecosystem in your AML Compliance work, contact us today to learn more about SURETY Eco, the end to end AML Ecosystem. You’ll be amazed at the power of innovative problem solving and Ecosystem Thinking to transform the effectiveness and efficiency of your AML Compliance efforts and achievements.