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

• Adds a check Vendor

  Check: Identity verification

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

  Check: Business verification

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

When the property is saved

• Runs a check Vendor or buyer

  Check: Same person on other cases

  When the property on the case is saved, eAML runs the check “Same person on other cases” on the person.

When contracts are exchanged

• Adds a check Buyer

  Check: Identity verification

  When contracts are exchanged, if the buyer is an individual, eAML adds the check “Identity verification” for the buyer, completed by staff.
• Asks for a document Buyer

  Document: Utility bill

  When contracts are exchanged, eAML asks for “Utility bill” from the buyer, as proof of address.
• Adds a check Buyer

  Check: Business verification

  When contracts are exchanged, if the buyer is a company, trust or other entity, eAML adds the check “Business verification” for the buyer, 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 Vendor or buyer

  Staff questions: Review of an expired ID

  When a check result comes back, 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 Vendor

  Check: Beneficial ownership

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

When owners or officers are recorded or changed

• Runs a check Vendor or buyer

  Check: Ownership structure complexity

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

  Check: Beneficial ownership

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

When contracts are exchanged

• Runs a check Buyer

  Check: Beneficial ownership

  When contracts are exchanged, if the buyer is a company, trust or other entity, eAML runs the check “Beneficial ownership” on the buyer.

Property & corporate records

Title, rates and registration records for the property or the entity.

When someone is added to the case

• Asks for a document Vendor

  Document: Council rate notice

  When a vendor is added to the case, eAML asks for “Council rate notice” from the vendor, to confirm the property and its owner.
• Asks for a document Vendor

  Document: Title search (current registered owner)

  When a vendor is added to the case, eAML asks for “Title search (current registered owner)” from the vendor, to confirm the current registered owner.

Financial & legal papers

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

When a bank account is added

• Runs a check Buyer

  Check: Size of the lending institution

  When a bank account is added for the buyer, eAML runs the check “Size of the lending institution” on the buyer.
• 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 the property is saved

• Runs a check Vendor

  Check: Income plausibility

  When the property on the case is saved, if the vendor is an individual, eAML runs the check “Income plausibility” on the vendor.

When a question is answered

• Runs a check Buyer

  Check: Income plausibility

  When an answer is saved for the buyer, if the buyer is an individual, eAML runs the check “Income plausibility” on the buyer.
• 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.
• Asks for a document Vendor or buyer

  Document: Evidence of the source of funds or wealth

  When an answer is saved, if either the person put the source of funds in the “Other” category or one of the other sources of funds the person listed is in the “Other” category or the person put the source of their wealth in the “Other” category, eAML asks for “Evidence of the source of funds or wealth” from the person, because the source of funds was recorded as “Other”.
• Asks for a document Buyer

  Document: Gift letter or statutory declaration from the giver

  When an answer is saved for the buyer, if a third party who is not clearly connected with the buyer will pay and the third party is a family member, eAML asks for “Gift letter or statutory declaration from the giver” from the buyer, about the third party who is paying.
• Asks for a document Buyer

  Document: Identity document of the person providing the funds

  When an answer is saved for the buyer, if a third party who is not clearly connected with the buyer will pay and the third party is a family member or unrelated to the buyer, eAML asks for “Identity document of the person providing the funds” from the buyer, about the third party who is paying.
• Asks for a document Buyer

  Document: Bank statement of the person or business providing the funds

  When an answer is saved for the buyer, if a third party who is not clearly connected with the buyer will pay and the third party is a family member, a related company or trust or unrelated to the buyer, eAML asks for “Bank statement of the person or business providing the funds” from the buyer, about the third party who is paying.
• Asks for a document Buyer

  Document: Loan agreement, deed of gift or resolution for the funding

  When an answer is saved for the buyer, if a third party who is not clearly connected with the buyer will pay and the third party is a related company or trust or unrelated to the buyer, eAML asks for “Loan agreement, deed of gift or resolution for the funding” from the buyer, about the third party who is paying.
• Asks for a document Buyer

  Document: Official register extract

  When an answer is saved for the buyer, if a third party who is not clearly connected with the buyer will pay and the third party is a related company or trust, eAML asks for “Official register extract” from the buyer, about the third party who is paying.
• Asks for a document Buyer

  Document: Lender's AUSTRAC enrolment and credit licence

  When an answer is saved for the buyer, if the lender is a non-bank lender, eAML asks for “Lender's AUSTRAC enrolment and credit licence” from the buyer, about the private or non-bank lender.
• Asks for a document Buyer

  Document: Signed loan agreement and mortgage documents

  When an answer is saved for the buyer, if the lender is a non-bank lender, a solicitor’s contributory mortgage fund or a private person, a group of investors or a lender based overseas, eAML asks for “Signed loan agreement and mortgage documents” from the buyer, about the private or non-bank lender.
• Asks for a document Buyer

  Document: The investors or trust behind the loan

  When an answer is saved for the buyer, if the lender is a solicitor’s contributory mortgage fund, eAML asks for “The investors or trust behind the loan” from the buyer, about the private or non-bank lender.
• Asks for a document Buyer

  Document: Bank statement of the person or business providing the funds

  When an answer is saved for the buyer, if the lender is a solicitor’s contributory mortgage fund or a private person, a group of investors or a lender based overseas, eAML asks for “Bank statement of the person or business providing the funds” from the buyer, about the private or non-bank lender.
• Asks for a document Buyer

  Document: Identity document of the person providing the funds

  When an answer is saved for the buyer, if the lender is a private person, a group of investors or a lender based overseas, eAML asks for “Identity document of the person providing the funds” from the buyer, about the private or non-bank lender.
• Asks for a document Buyer

  Document: Evidence of the private lender's source of wealth

  When an answer is saved for the buyer, if the lender is a private person, a group of investors or a lender based overseas, eAML asks for “Evidence of the private lender's source of wealth” from the buyer, about the private or non-bank lender.

Customer due diligence

The background questions every customer is asked.

When someone is added to the case

• Sends a form Vendor

  Form: Customer due diligence questions

  When a vendor is added to the case, eAML sends the vendor a form: “Customer due diligence questions” (32 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).

When contracts are exchanged

• Sends a form Buyer

  Form: Customer due diligence questions

  When contracts are exchanged, eAML sends the buyer a form: “Customer due diligence questions” (36 questions).

Enhanced due diligence

The extra steps for a customer rated higher risk.

When a question is answered

• Runs a check Buyer

  Check: Source of funds cross-check

  When an answer is saved for the buyer, if the buyer has declared how much they are contributing from this source of funds, eAML runs the check “Source of funds cross-check” on the buyer.
• Runs a check Vendor or buyer

  Check: Source of wealth cross-check

  When an answer is saved, if the person has declared their net worth, eAML runs the check “Source of wealth cross-check” on the person.

When a payment is recorded

• Sends a form Buyer

  Form: Source of funds declaration

  When a payment is recorded for the buyer, if a large payment has been recorded for the buyer, eAML sends the buyer a form: “Source of funds declaration” (9 questions).

Sanctions, PEP and adverse media

Watchlist screening and the country check.

When someone is added to the case

• Adds a check Vendor

  Check: Sanctions, PEP and adverse media screening

  When a vendor is added to the case, eAML adds the check “Sanctions, PEP and adverse media screening” for the vendor, started by an officer.
• Runs a check Vendor, 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 Vendor

  Check: Sanctions list cross-check

  When a vendor is added to the case, eAML runs the check “Sanctions list cross-check” on the vendor.
• 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.

When contracts are exchanged

• Adds a check Buyer

  Check: Sanctions, PEP and adverse media screening

  When contracts are exchanged, eAML adds the check “Sanctions, PEP and adverse media screening” for the buyer, started by an officer.
• Runs a check Buyer

  Check: Country risk

  When contracts are exchanged, eAML runs the check “Country risk” on the buyer.
• Runs a check Buyer

  Check: Sanctions list cross-check

  When contracts are exchanged, eAML runs the check “Sanctions list cross-check” on the buyer.

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 Vendor or buyer

  Staff questions: Staff risk assessment

  When a check result comes back, eAML asks staff to answer: “Staff risk assessment” (11 questions).
• Asks staff Vendor or buyer

  Staff questions: Review of an older client

  When a check result comes back, 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 the property is saved

• Runs a check Vendor

  Check: Quick resale

  When the property on the case is saved, eAML runs the check “Quick resale” on the vendor.
• Runs a check Vendor or buyer

  Check: Price against valuation

  When the property on the case is saved, eAML runs the check “Price against valuation” on the person.

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.