TABLE OF CONTENTS


What are Compliance rules?

Compliance rules allow you to configure requirements to be auto-added or suggested to cases based on rules/conditions that you set. 


There are default existing rules (e.g. where the entity type is Trust add Trust Deed as a suggested requirement). Users can also add specific rules based on various conditions (e.g. where the entity type is “Trust” add customised requirement ABC as a suggested requirement).


This allows compliance admins to ensure that manifest users e.g. frontline are always collecting the right documents and following the correct procedures as per their AML compliance programme.


Frontline staff will be guided by the configured prompts for ‘suggested’ or ‘required’ next steps based on pre-set conditions e.g. entity type, CDD level etc.




Which user roles can create compliance rules?

Source Compliance admins can create and configure new rules and edit and remove any default rules.


How do I create and edit compliance rules?

Compliance rules are in the Admin panel > Settings > Manifest section of the platform.

  1. Click ‘+ Add rule’ to the right of the Compliance Rules section.

  2. Name: The ‘Add compliance rule’ module will pop up. Users will be prompted to add a name for the rule. E.g. If PEP Match Positive > Enhanced CDD Rule’

  3. Related to: Select which entity type the rule should be applied to. The dropdown allows users to select Individual or Entity cases.

  4. When: Users can add conditions based on ‘Entity Type’ (e.g. Private Company, Trust etc.) and ‘CDD Level’ (Low, Medium or High) to determine the criteria for a requirement to be applied. To do so, click ‘+ Add condition’. There is no limit to the number of conditions that can be added. To delete conditions, click the blue ‘Delete’ icon.

  5. If no condition is selected, the rule will apply to all individuals and/or entities.

  6. Then: Users can select requirements that apply based on the set conditions above. You can type or scroll down the dropdown list of requirements. Any custom requirements added will also be present in this dropdown. Users can then select whether the requirement should be auto-accepted (i.e. added as default) or suggested (up to the Manifest user to decide if they want to accept the requirement).

  7. Click ‘Save’ to save the rule. The rule will now be applied to all cases.

Entity rules example showing rule creation and rule being applied


Individual rules example showing rule creation and rule being applied


What conditions are available?

Users can set conditions as to which rules apply to which clients.


Conditions are based on whether the rule is for individuals or entities.

  • Entity conditions are based on ‘CDD Level’, ‘Entity Type’, ‘Registered Country’, ‘Entity Property’, ‘Entity Verification Result’, ‘Office’ and ‘Risk Level’
  • Individual conditions are based on ‘CDD Level’, ‘Office’, ‘Risk Level’ and ‘Individual Verification Result’


Please note if no conditions are added, the rule will apply to all entities or individuals (based on the related to selection) in the case.


How do I edit, search and filter the compliance rules?

You can search and filter for all compliance rules within the Compliance Rules section. Users can start typing within the search bar to search.


Results can be further filtered by individuals or entities. To apply filters, click the ‘Apply filters’ button to the right. You can reset the filters by clicking the ‘Reset filters’ to show all rules.


Are there any default or existing compliance rules? Can I edit or remove them?

There are existing default rules within the platform. These can be accessed within the Compliance rules section when you first log into the Source platform. These rules are based on common compliance rules e.g. if the individual address failed electronic verification, suggest proof of address collection.


All rules can be edited and deleted. To do so, click the three dots to the right of each rule to show the ‘Edit’ or ‘Delete’ options.



Can First AML help me with creating compliance rules?

We are unable to prescribe specific compliance rules for our customers however we are able to refer you to trusted industry AML partners and consultants who will be able to suggest what rules your organisation should implement.


Things to note

What happens to requirements if conditions are changed?

  • Scenario: A rule is created to add a Shareholding chart suggested requirement if Entity Type = Fund. The manifest user then changes the entity type from ‘Fund’ to ‘Private Company’.

  • Whether the requirement is generated depends on whether the requirement has been added/accepted by the user.
    1. If the entity type is changed and the suggestion has not been accepted already then the suggested requirement will be dismissed (e.g. Fund to Private Company, shareholding chart requirement is suggested and then removed)

    2. If the entity type is changed and the suggestion has been accepted already then the suggested requirement will not be dismissed. (e.g. Manifest user accepts the ‘Shareholding Chart’ requirement when the entity type is marked as Fund. When the entity type is changed to ‘Private Company’ the shareholding chart requirement remains)

    3. If the system dismissed the requirement (see point 1), then if the entity type is changed back the requirement will be suggested again. (e.g. Manifest user changes entity type from ‘Fund’ to ‘Private Company’ and then back to ‘Fund’. The ‘shareholding chart’ requirement will reappear once the user changes the entity type back to ‘Fund’ in the last step)

    4. If the user dismissed or deleted the requirement, then if the entity type is changed back the requirement will not be suggested again. (e.g. Manifest user changes entity type from ‘Fund’ to ‘Private Company’ and then back to ‘Fund’. The ‘shareholding chart’ requirement was dismissed by the Manifest user when first suggested in step 1. The ‘shareholding chart’ requirement will not appear once the user changes the entity type back to ‘Fund’ in the last step)

    5. If the user accepts the requirement (see point 2), then if the entity type is changed back the requirement will not be suggested again. (e.g. Manifest user accepts the ‘Shareholding Chart’ requirement when the entity type is marked as Fund. Manifest user changes the entity type to ‘Private Company’ and then back to ‘Fund’. The ‘Shareholding Chart’ requirement will not be suggested again as it has already been accepted.)

Rules that add the same requirement type

  • Scenario: A rule is created to suggest a Source of Wealth requirement based on whether the case CDD level = Enhanced (Rule A). The manifest user dismisses this suggestion. Later, the admin adds another rule to suggest a Source of Wealth requirement if Entity Type = Trust (Rule B).

  • Result: Rule B would not add the Source of Wealth requirement as the Manifest user previously dismissed the Source of Wealth requirement.

  • When two rules add the same requirement e.g. Rule A & Rule B (above), we will only add the requirement to the case once. However, if one rule is a suggestion and one is an accepted requirement, then the accepted requirement will be added.

Conditions

  • Please note if no conditions are added, the rule will apply to all entities or individuals (based on the related to selection) in the case

  • If a user selects all CDD levels when creating a rule e.g. Rule A, and then creates a case with no CDD level then the rule (Rule A) will not apply to the case as there is no CDD level added.

  • Admins can also select multiple options within the same condition. This works as an “or” function e.g. CDD level is simplified OR enhanced then xyz…

  • Admins can also select multiple options under different conditions. This works as an “AND” function e.g. CDD level is simplified AND enhanced then xyz… Please note this will break the rule as a case can only have one CDD level applied at any one time. A case cannot be simplified AND enhanced at the same time.