AML/CFT Update

We’ve made some improvements to how CDD Candidates are selected in the Connectworks CDD workflow, to help you ensure that all beneficial owners and parties with authority to act on behalf of your clients are having their requirements met.

In the updated workflow you can:

  • Specify the type of relationship a CDD Candidate has to a client 

    • Relationships that can be selected are: Effective control; Authority to act; Transactions conducted on behalf; >25% ownership (companies only); and Other.

    • More than one relationship can be selected per candidate.

    • Buckets for each relationship (showing all candidates with a particular relationship to the client) are displayed below the selection box.

  • Record information about the nature of a Candidate’s beneficial ownership or authority to act on behalf of a client.

    • The new AML Relationships block in the Perform CDD section contains two groups of sub-field: AML Relationship information; and Authority to act. Each group can be completed either by entering information into it, or indicating that information is not required.

    • Where a candidate has not been flagged as having authority to act and/or beneficial ownership, the checkbox indicating that information is not required about that kind of AML Relationship is automatically checked.

  • Select companies and trusts as CDD Candidates

    • Companies & trusts have different kinds of identifying information than natural persons. This is reflected on their Identity Verification block.

    • Where one company or trust client has a beneficial ownership relationship in another, its completed CDD record can be reused to create the identity verification, linking the records together. 

Important Information

If you’ve completed CDD for a client, you don’t have to do anything - completed records aren’t affected by the new fields. 

Existing CDD Candidates

All existing CDD candidates in ongoing workflows will be automatically marked as having an ‘other’ AML-relationship to the client. This relationship can be modified in the CDD Candidates section.

All existing Candidates will also have a new AML Relationships block in the Perform CDD section, which will be incomplete by default. You can complete this section by recording information about the Candidate’s AML relationship to the client, or by flagging that further information is not needed.

Linking previously-completed CDD records

If you have trust or company clients with beneficial ownership relationships to other clients, you can reuse their completed CDD records to verify their identity when performing CDD on the other client. For example, if you have a trustee company with a relationship to a number of trusts, you can perform CDD on the trustee company, then link that record into the CDD records of the trusts it is involved in.

To do this, just select the trust or company as a CDD candidate, then click the button to verify its identity information. If it’s had CDD completed, you’ll be able to use it here to create a new identity record. 

When reviewing and confirming the CDD, the reviewer can see whether a company/trust Candidate has had a full workflow completed by looking at the Identity Determination section of the Summary Review form. CDD Candidates whose identity determinations are based on completed CDD Workflows have an extra line of text stating this.