Keeping due diligence up to date
Summary
A member's file describes them on the day it was made. This lesson is how to notice when today's behaviour stops matching it.
About 3 minutes · 5 steps. Also called: ongoing due diligence, ongoing monitoring, re-rating, review.
Prerequisites
- Customer due diligence and the risk-based approach — the levels this lesson keeps current.
- Access to member records, or a role in Wakandi AML Risk Monitoring.
Step-by-step
Put behaviour beside the story. Sign in to Wakandi AML Risk Monitoring and open the member under Customers, or pull their file, and compare recent activity with what they said they do.
Figure 1: A member's AML profile, with recent transactions beside the identity details and risk score Keep the list of what raises risk close at hand:
- A cash-heavy business.
- A member acting for someone else.
- A prominent public position, or closeness to one.
- An arrangement more complicated than the stated business needs.
- Weak documents, or a story that keeps changing.
- A sector your policy marks higher-risk.
Watch for the changes that call for a re-rate:
- Money from places the member never dealt with before.
- Volumes far above their pattern.
- A changed stated business.
- A connection to someone under review.
- A case opened on them in Wakandi AML Risk Monitoring.
Move the rating when behaviour moves, upwards or downwards, and record the reason while it is fresh. A stale rating is a risk of its own, and a written reason lets the file answer for you later.
Take mismatches to your compliance officer rather than deciding alone, and say nothing to the member about the review.
Note: A rating moves both ways. Recording a drop in risk, with its reason, is as valuable as recording a rise.
Common pitfalls & FAQ
- "Once a member is rated, the rating stays." A rating describes one moment. When behaviour changes, review it.
- "A long-standing member does not need checking." Length of membership is not evidence of low risk, and long trust is exactly what a launderer borrows.
- "A member holds public office — is that a problem?" It is a reason for more care, not an accusation. The next lesson covers politically exposed persons.