Checks, questions and documents

Customer identification

Who they are: the identity check, the ID document, proof of address.

When someone is added to the case

• Runs a check

  Check: Same person on other cases

  When someone is added to the case, eAML runs the check “Same person on other cases” on the person.
• Adds a check Client

  Check: Identity verification

  When a client is added to the case, if the client is an individual, eAML adds the check “Identity verification” for the client, completed by staff.
• Adds a check Client

  Check: Business verification

  When a client is added to the case, if the client is a company, trust or other entity, eAML adds the check “Business verification” for the client, started by an officer.
• Asks for a document Client

  Document: Utility bill

  When a client is added to the case, eAML asks for “Utility bill” from the client, as proof of address.
• Adds a check Owner, officer or representative

  Check: Identity verification

  When an owner, officer or representative of the customer is added to the case, if the person is an individual, eAML adds the check “Identity verification” for the person, completed by staff.
• Adds a check Owner or officer

  Check: Business verification

  When an owner or officer of the customer is added to the case, if the person is a company, trust or other entity, eAML adds the check “Business verification” for the person, started by an officer.

When a check result comes back

• Runs a check

  Check: ID expiry

  When a check result comes back, if “Identity verification” has a result, eAML runs the check “ID expiry” on the person.
• Asks staff Client

  Staff questions: Review of an expired ID

  When a check result comes back for the client, if the ID document had expired when it was verified, eAML asks staff to answer: “Review of an expired ID” (3 questions).

When a payment is recorded

• Runs a check

  Check: Same person on other cases

  When a payment is recorded, eAML runs the check “Same person on other cases” on the person.

Beneficial ownership

Who owns or controls a company or trust, and how complicated the structure is.

When someone is added to the case

• Runs a check Client

  Check: Beneficial ownership

  When a client is added to the case, if the client is a company, trust or other entity, eAML runs the check “Beneficial ownership” on the client.

When owners or officers are recorded or changed

• Runs a check Client

  Check: Ownership structure complexity

  When owners or officers of the client are recorded or changed, if the client is a company, trust or other entity, eAML runs the check “Ownership structure complexity” on the client.
• Runs a check Client

  Check: Beneficial ownership

  When owners or officers of the client are recorded or changed, if the client is a company, trust or other entity, eAML runs the check “Beneficial ownership” on the client.

Source of funds and wealth

Lenders, bank statements, source of funds and source of wealth evidence.

When a bank account is added

• Runs a check

  Check: Source of funds against the bank balance

  When a bank account is added for a person, eAML runs the check “Source of funds against the bank balance” on the person.

When a question is answered

• Runs a check

  Check: Source of funds against the bank balance

  When an answer is saved, eAML runs the check “Source of funds against the bank balance” on the person.

Customer due diligence

The background questions every customer is asked.

When someone is added to the case

• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if no designated service has been recorded for the case, eAML sends the client a form: “Customer due diligence questions” (35 questions).
• Sends a form Owner or officer

  Form: Questions for an owner or officer

  When an owner or officer of the customer is added to the case, eAML sends the person a form: “Questions for an owner or officer” (4 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Selling, buying or transferring a business entity (item 2)” and the firm does not act for the buyer or seller, eAML sends the client a form: “Customer due diligence questions” (41 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Holding or controlling a client's money or assets (item 3)”, eAML sends the client a form: “Customer due diligence questions” (38 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Equity or debt financing (item 4)”, eAML sends the client a form: “Customer due diligence questions” (37 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Selling or transferring a shelf company (item 5)”, eAML sends the client a form: “Customer due diligence questions” (36 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Creating or restructuring a company or legal arrangement (item 6)”, eAML sends the client a form: “Customer due diligence questions” (36 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Acting as a nominee director, secretary, partner, trustee or corporate attorney (item 7)”, eAML sends the client a form: “Customer due diligence questions” (36 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Acting as a nominee shareholder (item 8)”, eAML sends the client a form: “Customer due diligence questions” (36 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Providing a registered office address (item 9)”, eAML sends the client a form: “Customer due diligence questions” (36 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Selling, buying or transferring a business entity (item 2)” and the firm acts for the buyer, eAML sends the client a form: “Customer due diligence questions” (38 questions).
• Sends a form Client

  Form: Customer due diligence questions

  When a client is added to the case, if the service is “Selling, buying or transferring a business entity (item 2)” and the firm acts for the seller, eAML sends the client a form: “Customer due diligence questions” (39 questions).

Sanctions, PEP and adverse media

Watchlist screening and the country check.

When someone is added to the case

• Adds a check Client

  Check: Sanctions, PEP and adverse media screening

  When a client is added to the case, eAML adds the check “Sanctions, PEP and adverse media screening” for the client, started by an officer.
• Runs a check Client, and owner, officer or representative

  Check: Country risk

  When someone is added to the case, eAML runs the check “Country risk” on the person.
• Runs a check Client

  Check: Sanctions list cross-check

  When a client is added to the case, eAML runs the check “Sanctions list cross-check” on the client.
• Adds a check Owner, officer, representative or funder

  Check: Sanctions, PEP and adverse media screening

  When an owner, officer, representative or funder of the customer is added to the case, eAML adds the check “Sanctions, PEP and adverse media screening” for the person, started by an officer.

Risk scoring and tiering

The overall rating, the factors behind it, and the officer’s decisions.

When a case is opened

• Needs a decision

  Decision: Risk rating decision

  When a case is opened, eAML asks an officer to decide: “Risk rating decision”.
• Needs a decision

  Decision: Senior officer approval

  When a case is opened, eAML asks an officer to decide: “Senior officer approval”.

When someone is added to the case

• Runs a check

  Check: Age check

  When someone is added to the case, if the person is an individual, eAML runs the check “Age check” on the person.

When a person’s details change

• Runs a check

  Check: Age check

  When a person’s details are changed, if the person is an individual, eAML runs the check “Age check” on the person.

When a question is answered

• Asks staff Owner or officer

  Staff questions: PEP assessment

  When an answer is saved, if the person says they, a family member or a close associate is a politically exposed person (PEP), eAML asks staff to answer: “PEP assessment” (1 question).

When a check result comes back

• Asks staff Client

  Staff questions: Staff risk assessment

  When a check result comes back for the client, eAML asks staff to answer: “Staff risk assessment” (11 questions).
• Asks staff Client

  Staff questions: Review of an older client

  When a check result comes back for the client, if the person is elderly, eAML asks staff to answer: “Review of an older client” (2 questions).
• Asks staff Owner, officer or representative

  Staff questions: PEP assessment

  When a check result comes back, if screening found a possible politically exposed person match, eAML asks staff to answer: “PEP assessment” (1 question).

On the case

Checks on payments and the property, and the case-level banner.

When a question is answered

• Runs a check

  Check: Who paid and from where

  When an answer is saved, if the person has named the countries outside Australia their wealth came from, eAML runs the check “Who paid and from where” on the person.
• Runs a check

  Check: Who paid and from where

  When an answer is saved, if an officer has recorded what the bank statement shows about who paid the money in, eAML runs the check “Who paid and from where” on the person.

When a payment is recorded

• Runs a check

  Check: Who paid and from where

  When a payment is recorded, eAML runs the check “Who paid and from where” on the person.
• Runs a check

  Check: Refunds

  When a payment is recorded, if the payment is a refund, eAML runs the check “Refunds” on the person.