First AML will complete the Customer Due Diligence process per the Standard Operating Procedure in accordance with the AML legislation. Noting that the legislation does have some room for interpretation and judgement a risk-based approach should be taken for each case.
The ultimate approval of a case should be made in accordance with a Reporting Entity’s compliance programme, risk assessment and any other internal controls that may be in place.
Once a case is completed by First AML, it will be placed in the ‘Ready for Review’ section of the platform. Then, the elected Case Approver will receive an email to review the case. When the case is in this status, you will have to review the information and ensure that you are happy with the information collected. Once you have reviewed the case, you can approve the case and move it into "completed" status.
TABLE OF CONTENTS
Open the case and check that you are happy with the information collected and any special notes raised by the First AML team. It is ultimately your responsibility to make sure you are happy to proceed with the information collected.
You are able to check all information using the 'review' function which is displayed at the top of your case as a clipboard icon.
When you click this review button all individual information, entity information, and any case notes, will be displayed for you to check by clicking into each section.
When you scroll down you can see all underlying documents such as the Verification Report, ID documentation, the biometric image, and then any notes that our First AML team have picked up.
As you review the information you can click the checkbox on the left hand side. After checking the individual information you can review the entities.
Scroll down to see the documentation which has been uploaded for each entity e.g. the company extract.
At the end of the review panel you can check any notes which have been left by the First AML team.
Once you have reviewed all information, click out of the review panel and click on "Approve" to move the case into the completed section.
You can now view the completed case under the "completed" section on the homepage after filtering to "Completed".