TABLE OF CONTENTS

This article outlines one approach to configuring this in First AML for Australian customers. It is intended as general guidance rather than prescriptive instructions. 

The structure of your cases and the individuals you verify depend on your organisation's compliance programme and the legislation applicable in your jurisdiction.


In a mortgagee in possession sale, the entity exercising the power of sale (typically a bank) is the party you verify, rather than the original property owner.


Before you start

The case should be created under the entity that holds the power of sale, not the original owner. As this is often a publicly listed bank, simplified CDD may apply depending on your compliance program.


Create the case

  1. Start a new case for the property, and select your verification type.
  2. Select Entity, then Public Company (or the appropriate entity type for the entity exercising the power of sale).
  3. Enter the entity's name, registered country, and the contact person acting on its behalf.
  4. Select Go to case.


Build the structure

Unwrap typically isn't needed for this scenario. Instead:

  1. Select Edit structure and add the individual acting on behalf of the bank.
  2. Set their relationship type to Acting on behalf.


Collect requirements

Typical documents to collect include:

  • Evidence of the entity's execution of rights for mortgagee sale
  • Authority to act, for the individual representing the bank
  • Identity verification for that individual; your compliance program determines whether this is a simplified screening-only check or a full verification including biometrics and ID anti-tampering checks


You may also choose to screen the bank itself, depending on your compliance program.