Guide, for the Advisor

Keep a due diligence file on a client

Record who a client company is, who owns and controls it, their ID and PEP answers, a sanctions screening and the risk, then sign the file off.

Where: Your workspace, Clients

1. 1

   Open the file

   In Clients, each company shows Due diligence and where its file stands. Choose it, then Open the file. The file starts with the company's name, ABN and ACN, and the directors and secretary the company has recorded.

   Only your firm can see the file. The company never can, before or after it is handed to the founder.

2. 2

   Verify the company

   Under The company, press Check the ABR to look the ABN up on the Australian Business Register and keep what it said. Then press Record verification and say what you checked, for example the ASIC company extract you sighted.

3. 3

   Add the owners and controllers

   Under Owners and controllers, anyone on the register with 25% or more is listed with an Add button. Add them, and anyone else who controls the company, with Add a person. For an entity that owns shares, add the people behind it rather than the entity. Someone who no longer owns or controls the company is taken off the file from the row's menu; their record stays in the export.

4. 4

   Record ID and the PEP answer for each person

   Press Record ID on each row once you have sighted an original or certified document, and choose which one. Then press Answer and record whether the person is a politically exposed person, and their public role if they are.

   Do not type document numbers into Struck. Keep the copy under your firm's own program.

5. 5

   Screen everyone against the sanctions list

   Under Sanctions screening, press Screen everyone. The company and every person on the file are checked against the DFAT Consolidated List, and each result shows No match or Possible match. For a possible match, press Resolve, compare the listing with what you know, and record that it is not the same person, or that it is, and why.

   A confirmed match means stop work for the client and follow your firm's program. Never tell the client why.

6. 6

   Record the purpose and risk

   Under Purpose and risk, say what the relationship is for, choose a Risk rating and set the Next review date. Choosing a rating suggests a date: a year for high, two for medium, three for low. A high rating needs a reason. Press Save assessment.

7. 7

   Sign the file off

   When every item in the Checklist is ticked, press Sign off the file. The file reads Complete on Clients until its review date, then Review due. From a month before that date, the notification bell and the weekly digest email remind everyone at your firm, until the review is done and the file signed off again with a new date. Any later change to the people, the screening or the assessment reopens it. Export downloads the whole file, including its history, as a spreadsheet.