Client onboarding, with AML focus

45 mins

A robust onboarding agenda that incorporates the internal considerations required when it comes to AML (anti money laundering).

Jacques Malan

Jacques Malan

Managing Director, XAMA Technologies

Your company and our relationship (5 min)

Cover the registration and filing requirements of your business and whether these are all up to date. We will also confirm the primary purpose of your business and ensure that we are a good fit as a provider.

Questions to consider

  • Is the business registered with companies house or similar authority?
  • Is filing and PSC register up to date?
  • What is the primary purpose of the business?
  • How did the business get to know about us as a provider?
  • Does it make sense for us to have a business relationship?

Owners of the business (10 min)

Confirm the ultimate beneficial owners of the business and identify the ownership structure of the business.

Questions to consider

  • Who are the shareholders?
  • Who are the directors?
  • Does any complicated ownership structure exist?
  • If so, what are the reasons for setting up the ownership structure as it has been done?
  • Are any owners considered to be politically exposed?

Business activities (10 min)

Ensure we understand all the activities undertaken by the business such that we can ensure we can provide the best support.

Questions to consider:

  • Will the business be engaging in any high risk activities such as:
  • Trading in high value items such as yachts, art, precious metals.
  • High volumes of cash transactions, such as is found within antique dealerships, nail salons and hairdressers.
  • Does the business engage in any activities or operate within sectors which we as a supplier are not familiar with.
  • Do they require any services which we do not normally offer, such as management of crypto transactions.
  • Do they require any of our services which we do offer, but we consider to be higher risk.
  • Does the business have a higher than expected number of bank accounts, if so what is the reason.

Geographical areas of operation (10 min)

Understanding if there are any regions your business operates within which is not part of the normal jurisdiction in which we operate.

Questions to consider:

  • Does the client operate in any regions:
  • Which does not fall within our normal jurisdiction.
  • Falls within any jurisdiction which are considered at higher risk of money laundering (third countries)
  • Does any of the shareholders or corporate ownership fall within a jurisdiction considered to be higher risk.

Our ongoing communication (5 min)

Establish your preference on communications and whether we will have access to the executives of the business or primarily work via an intermediary.

Any other items (5 min)

We may need to cover some additional items as part of our discovery call if needed. This might include more information about the source of funds to finance a particular transaction, as example.

Enhanced due diligence

Depending on the conversation thus far, it might be necessary to cover some additional items. Not all will be possible as part of the onboarding call, but may include:

  • More in depth explanations of the source of funds or source of wealth and the way in which they can provide evidence of this. E.g. bank statements.
  • Gather more evidence of beneficial ownership and establish valid reasons why it might not be possible to contact one of the beneficial owners.
  • If not registered with a known authority, further evidence of the identity of the company.
  • Is there any reason to believe that there is adverse media for the client or any other negative information, such as CCJs.
  • Is there any additional AML measures that you will put in place (E.g. require additional documentation) which the client need to be made aware of.

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Client onboarding, with AML focus agenda template summary

An onboarding meeting agenda incorporating questions and elements to ensure an effective Anti-Money Laundering (AML) process is followed. This agenda template is provided by AML platform Xama technologies and is best edited to follow your own organisations AML process. The boxes provided are intended as internal prompts for the agenda and can be added to private or team notes.