It’s never been more important to keep on top of your AML compliance as an accounting firm.
AML compliance regulations and requirements constantly evolve, yet a large number of us are still managing our compliance in manual, disconnected ways.
If you’re looking for ways to streamline your AML onboarding process, Firmcheck can help you do exactly that. It's fast and straightforward from your firm's perspective, and when it comes to the client experience, running ID checks has never been easier and they won’t be expected to download an app to verify an ID or address document simply.
In this post, we'll give you the lowdown on using Firmcheck for client onboarding, with a step-by-step guide.
What are your AML responsibilities as a firm?
Checking for potential for money laundering, fraud and criminal activity is a key requirement when taking on a client. In part, this is down to the firm’s responsibility to counter the rise in these illegal activities. But also it’s about protecting the trust your clients place in you as an adviser and safeguarding the brand reputation of your accounting firm.
As a firm, you have an ongoing responsibility to:
- Have a documented AML compliance policy
- Conduct thorough risk assessments
- Implement customer due diligence (CDD) procedures
- Regularly train your employees
- Implement ongoing due diligence and reporting
The good news is that we’ve got most of that covered in Firmcheck, from the first onboarding step to the risk assessments, CDD processes and training of your practice staff.
But for this post, let’s dive into the initial client onboarding and how to use Firmcheck for first time clients.
How to run AML checks using Firmcheck
Onboarding new clients using Firmcheck is about reviewing the potential risk of engaging with a client, and having a documented ‘paper’ trail in place. Using our tools, you can assess the potential risk and determine whether it’s in your firm’s interest to onboard any particular client.
Let’s take a look at how this process works:
1. Onboarding your prospective client
The first thing to do is add your prospect to Firmcheck for onboarding - this could be a business, individual, charity etc. (we give you the option to choose what type of client your onboarding and the flow adjusts accordingly).
For this post, we’re going to follow the steps as if you’re onboarding a business.
2. Create, search or import
At this stage, you now have three options. You can:
- Create an entity from scratch,
- Search for an existing entity in Firmcheck, or
- Import an entity (and all its associated parties) from Companies House.
Firmcheck’s Companies House integration makes this whole process much easier to do. You can quickly search for a client via Companies House and use the existing data to pre-populate the prospect's contact details.
3. Begin the onboarding workflow: the profile tab
Once you’ve located the client you’re trying to onboard from the Companies House data you can now import the client into Firmcheck to start working through your onboarding workflow.
In the profile tab, all the available Companies House information will automatically populate the relevant fields, including:
- General details about the company
- Contact details of associated individuals or parties, specifically Persons of Significant Control (PSCs) and Directors
You also have the opportunity to attach the client to specific groups, services or staff within your firm using the client admin and services tab (this is a popular feature for larger firms who might have multiple offices in different locations but want to keep all their AML compliance in one system).
4. Onboarding: the AML/CFT tab
Once you've confirmed everything is as it should be in the profile tab, the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) tab is your next stop.
In the AML/CFT tab several steps form part of your overall risk assessment about the client, and the parties you’re onboarding.
In the tab you'll be able to perform Customer Due Diligence (CDD) on the required individuals, complete your risk assessment, and make your determination on the risk levels of this prospect.
5. Onboarding: collecting and verifying information
While still in the AML/CFT tab, you can collect and verify any necessary documents or IDs.
These documents and IDs may include:
- AML/CFT relationships
- PEP and personal source of wealth
- A passport or a drivers licence
You can also run full biometrics, PEPs and sanctions checks through Firmcheck, to further verify the prospect, the organisation and their interested parties.
Below is an example of the biometric experience from a client's perspective.
In the documents tab, you can also upload or link to any other documents that you might have gathered already as part of your KYC process, you’d expect to use the documents area for information relating to the company, whereas any personal information that is relevant to an individual is stored in the ‘Perform CDD’ section.
6. Onboarding: deciding whether to proceed
Once you've completed your due diligence on the prospect and captured and verified any IDs, you’re then at a key point in the AML process. By looking at the various components of your risk assessment, you can review the evidence and make a determination on how to proceed.
1) Do you determine that the risk level is acceptable and that you can proceed with the engagement?
2) Do you determine that the risk level is too high, and that it’s not in the firm’s interest to engage?
7. The approval tab
Once you've completed all the steps in the new client workflow, you can submit your determination for approval as per your firm's AML policies and procedures.
This will likely involve submitting it for approval from your nominated compliance officer or Money-Laundering Reporting Officer (MLRO).
To ensure you’re following your firm’s AML procedures, you can choose who your AML determination will be sent to for approval. You can also leave a note for the approver, with additional details, concerns or information that’s relevant to the approval process.
8. Approval from your compliance officer/MLRO
Once you select your approver and send your final determination, this will then send an email notification to the relevant approver, with a direct link to the determination they need to review. They’ll also be able to see any other outstanding reviews in their dashboard. The approver can click through to review all the client information, documents and notes you’ve added as part of your assessment of the prospective client.
Based on the details of your assessment and determination, your approver can then make the final call on this prospect. They can either approve or reject your recommendation, based on the information available. The decision, of course, will dictate whether or not you choose to onboard the client.
The final step is to hit the submit button, confirming the approver’s decision in the system. All the information, documents and notes you completed during the workflow are saved in Firmcheck for future reference, regardless of the outcome you can be confident you’ve got a documented decision should you need to show proof at a later date.
9. Success! You’ve completed an onboarding assessment
That’s it, in a few simple steps you’ve consolidated your AML onboarding process into one tool, and you’ve got a track record demonstrating you’re hitting your compliance obligations.
You’ll find your new clients information in the client dashboard under ‘Completed CDD’ – this is where you’ll find all of your clients whom you’ve made a determination against in Firmcheck.
The bonus is that now you’ve got your client's information into Firmcheck, carrying out future due diligence, or repeat checks is so much easier.
Firmcheck: the simple way to streamline your AML compliance
Firmcheck is your go-to system for AML management – take the stress out of AML compliance, move away from manual data entry, disconnected systems and the headaches that come with that. And, we also offer free online AML training to help you meet those AML training requirements, plus AMLia, an online chatbot that is designed to be your 24/7 AML assistant for simple FAQs when you just need some guidance.
If your accounting firm is looking to take some of the pain out of your AML compliance, we think Firmcheck can help 😉. Book a quick 20-minute demo and find out just how simple your AML compliance process could be.
P.S. Want to try this workflow out for yourself – you can below ⬇️
(NB: This article doesn't constitute legal advice and is only intended for general informational purposes. Always consult with a legal expert or compliance consultant for guidance specific to your firm.)