Client due diligence

A firm that helps a company raise capital is a reporting entity under the AML/CTF Act, and its customer is the company. Due diligence, opened from a client's row on Clients, is the firm's file on that company: how the company was verified (with a check of its ABN on the Australian Business Register), the people who own 25% or more or control it, a record that each person's identity document was sighted and whether they are a politically exposed person, a screening of the company and every person against the DFAT Consolidated List, the purpose of the relationship, a risk rating and a review date. A possible sanctions match stays open until someone records whether it is the same person and why. The Checklist ticks each step from what the file records, and Sign off the file is refused until all of them are done; a later change reopens it. From a month before a signed-off file's review date, the firm's notification bell and weekly digest remind them, and the file reads Review due once the date passes. Concerns records the team's worries about the client. On each raise the firm runs for the client, Investor checks shows the file's status to the firm's own people, with a link to it. Only the firm can see the file, never the company, because telling a customer about a suspicion can be the offence of tipping off. Nothing in the file is deleted, and Export downloads all of it, history included, for the seven years the records must be kept. Struck keeps the record; the checks and the judgements are the firm's, and Struck does not search PEP lists.