Recording AML/CTF Data against a Business Sponsor

Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws are designed to detect, deter, and disrupt money laundering, terrorism financing, and proliferation financing. The legislation requires businesses that provide a 'Designated Service' to perform and record Customer Due Diligence (CDD).

Migration Manager allows the ability to record details of CDD on Matters and notify your AML/CTF Compliance Officer when a Risk Assessment is set as high.

The 'AML/CTF Risk Assessment' tab

To enter AML/CTF data against a Business Sponsor, first open the Sponsor Matter, then navigate to the AML tab.

Prescribed Service

Tick this Box if you are assisting the Sponsor with a Prescribed Service.  This will activate functionality against the Matter to trigger AML/CTF notifications and reporting.

Note: You can still use the other fields on this tab to record Customer Due Diligence even if Prescribed Service is not ticked. Leaving Prescribed Service un-ticked means features such as Notifying the Compliance Officer of a High Risk or reaching the Cash Threshold will not be activated.

Verification and Checks

Company Verification. Tick this box once you have completed the Company Verification.  Select the Date the verification was completed and which Staff member that completed it.

Company Verification Document 1 and 2. Select the relevant Document Type from the drop-down-list.

Link to the relevant document.

  1. Click the more icon to open the Select File window.
  2. Here you can either Select an existing document from the Matter, or click Browse to browse your computer if the document is in a different location.  

Note: Once the document has been linked, you can open it directly by clicking on the link, or clear the link by clicking Clear.

Beneficial Owners Check. Tick this box once you have completed the Beneficial Owners Checks.  Select the Date the checks were completed and which Staff member completed them.

Beneficial Owners ID Document. Select the relevant Document Type from the drop-down-list.

Link to the relevant document.

  1. Click the more icon to open the Select File window.
  2. Here you can either Select an existing document from the Matter, or click Browse to browse your computer if the document is in a different location.  

Beneficial Owners PEP. Tick this box once you have completed the Beneficial Owners Politically Exposed Person Checks.  Select the Date the checks were completed and which Staff member completed them.

Beneficial Owners Sanctions. Tick this box once you have completed the Beneficial Owners Sanctions Checks.  Select the Date the checks were completed and which Staff member completed them.

Initial Risk Assessment

  • Initial Risk Assessment Completion.  Once Initial Risk Assessment is complete, select the Date and the Staff member who completed the Assessment.
  • Initial Risk Assessment Rating. Set the the rating to Low, Medium or High.
  • Initial Risk Assessment Notes.  Enter any notes relating to this assessment.

If you set the Initial Risk Assessment to High, a pop-up will appear asking if you would like to notify the AML Compliance Officer by email.  Click Yes to notify them and create an email.

Ongoing Risk Assessment

  • Ongoing Risk Assessment Completion.  Once Ongoing Risk Assessment is complete, select the Date and the Staff member completing the Assessment
  • Ongoing Risk Assessment Rating. Set the the rating to Low, Medium or High.
  • Ongoing Risk Assessment Notes.  Enter any notes relating to this assessment.

If you set the Initial Risk Assessment to High, a pop-up will appear asking if you would like to notify the AML Compliance Officer by email.  Click Yes to notify them and create an email.

Closing Risk Assessment

  • Closing Risk Assessment Completion.  Once Closing Risk Assessment is complete, select the Date and the Staff member completing the Assessment.
  • Closing Risk Assessment Rating. Set the the rating to Low, Medium or High.
  • Closing Risk Assessment Notes.  Enter any notes relating to this assessment.

If you set the Initial Risk Assessment to High, a pop-up will appear asking if you would like to notify the AML Compliance Officer by email.  Click Yes to notify them and create an email.