TABLE OF CONTENTS


Summary

In this article we have some recommendations that we think will allow you to utilise the Source platform and the available features, this article will be updated often if we have additional recommendations for new features or processes. 


This is article is recommendations about using the Source platform, none of this is advisory on how to complete AML verifications on your clients. Ensure you are consulting your compliance program if you are unsure on next steps. 


User roles

We do have the recommendations of the user roles Compliance Admin, Compliance Approver, Compliance Office Member and Frontline. If you would like further information about the user roles and what their permissions are within the Source platform please read more in the about user roles


Client communication 

Communicate with your clients that you will be requesting that information is provided to complete the AML verification process and that this will come from the Source platform. Handy tip is to ensure your email branding is up to date with logo, colouring and any specific template updates more information on email templates


Custom requirements

While your source platform will come preloaded with a number of requirements which we have found are part of AML verifications, we also understand that you may have additional requirements which you can also request from Source. We recommend putting time in at the start to add any requirements you might like to also request from Source. 


We have clients requesting additional information, tax residency status, occupation, and also including hyperlinks to their own terms of engagement. 


More on custom requirements 


Compliances rules

Compliance rules also comes with a number of preloaded rules, however we understand there might be minor tweaks to the existing rules or the creation of brand new ones also inline with any additional requirements you have created. 


Setting up as many relevant compliance rules can ensure that the users within your Source platform are pointed in the right direction of what information and documentation to collect under different circumstances that your clients might be presenting.


More on compliance rules


Setting up offices 

It is best for you to create your offices before adding users when you first have access to the Source platform. If you would like to add offices after your users have been created please reach out to First AML at help@firstaml.com 


Offices are commonly set up as location but we also see some of our clients setting them up for workstream i.e. Trust, Estate, Conveyancing. 


Having offices is also a way that you can set up what users within your Source platform can and can't see. 


Screening profiles 

Screening profiles is a configuration which allows you to have some control about what your clients are screened against when you are running checks. 


You have the option of four different screening profiles, you are in control of the fuzziness levels at a company and office level and you can toggle on or off adverse media at a company level.


We see clients who have offices set up for workstreams using different levels of screening profiles across lower and higher risk workstreams.


More about screening profiles


Ongoing Monitoring

You are able to toggle on the continuous monitoring within your configurations and you will then receive notifications on new and changing matches within your databases of screened individuals and entities.  

 

More about ongoing monitoring


Passing individuals and entities 

Ensuring that you pass individuals and entities as you complete work is important for several reasons: 

1. This flows into the reporting which you would be providing for your annual reports

2. This ensures you can retrieve information into new cases if you have clients you might verify for multiple matters 

3. This allows users to keep track of what else is required in the case 


There are some instances which an individual will automatically pass and this is if the verifications are completed and there are no additional documents required. If there is manual intervention required or there are customer requirements for additional information you would likely need to manually pass individuals. 





Trusts in shareholding

Identifying trusts in shareholding can sometimes be difficult as there is no universal way for the trusts to be shown within a company extract. 


Within Australia and New Zealand there are a couple of signs that a company may have a trust in shareholding some are around the shareholding structure and how it is shown in Source and others are around the name of the entity in shareholding of the company. 


If Source unwraps a separate entity which is titled 'joint shareholding' the individuals who are within that structure may well be holding the shares on behalf of a trust. 




If the company which is unwrapped in the shareholding has the word 'trustee' in the company name, then that company may be holding shares on behalf of a trust. 


This is an Australian company specific tip, if you have unwrapped the company and Source has provided an alert that the shares are not held beneficially, this is an indicator that the individual or company which has been unwrapped are holding shares on behalf of a trust. 



If you are ever unsure if there is a trust in shareholding we recommend having that discussion with your client to ensure you are verifying all those who have effective control or beneficial ownership over the entity you are onboarding.