TABLE OF CONTENTS


Summary

In this article we have some recommendations that we think will help 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 includes recommendations about using the Source platform only, 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 recommend the user roles Compliance Admin, Compliance Approver, Compliance Office Member and Frontline. If you would like further information about user roles and their permissions please read here: user roles. 


Client communication 

Communicate with your clients that you will be requesting information to complete the AML verification process, and that this request 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. For more information: 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. We recommend adding your extra requirements early. 


Some of our clients choose to request additional information, tax residency status, occupation, and also include hyperlinks to their own terms of engagement. 


More on custom requirements 


Compliances rules

Compliance rules come with a number of preloaded rules, however we understand you may want to make minor tweaks to the existing rules or the create brand new ones inline with your compliance program. 


Setting up as many relevant compliance rules as possible ensures that the users within your team are pointed in the right direction in terms of which information and documentation to collect under different circumstances.


More on compliance rules


Setting up offices 

It is best to create your offices before adding users when you first have access to Source. If you would like to add offices after your users have been created please reach out to First AML at [email protected] 


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 also enables you to control which cases are visible to certain users depending on their role. More about offices


Screening profiles 

Screening profiles is a configuration which allows you to have some control over what your clients are screened against when you run 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 can toggle on the continuous monitoring within your configurations, 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 

4. You may also have automations set up around requirements or individuals being completed/passed. 


There are some instances which an individual will automatically pass e.g. 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.

 




Automation rules

Our automation rules feature allows you to set up automated actions based on specific conditions, ensuring that key tasks like verifications and screenings happen automatically when triggered. Automating routine tasks within your compliance workflows can help you reduce manual clicks and streamline onboarding. 


More about the automation rules



Trusts in shareholding

Identifying trusts in shareholding can sometimes be difficult as there is no universal way for the trusts to be displayed 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 could be holding shares on behalf of a trust. 



If you are ever unsure whether 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.