Concept
Know your customer and AML
What the firm must hold about each client under its own rule, how the risk band is set and confirmed, and how reviews and internal concerns work.
The Anti-Money Laundering Act, 2020 (Act 1044) asks the firm to know who it acts for. The system keeps that knowledge on each party's KYC tab and tells the firm what is missing.
What the firm holds
The firm decides, per kind of party, what it must hold: for a person perhaps a GhanaCard and proof of address, for a company its registration, directors and beneficial owners. The KYC tab shows what is held and what is still missing against that rule.
- Identity documents, each with its reference, expiry and scan. Each scan is also filed in the documents register on the party, as an identity document tagged
kyc, and a new scan becomes its next version; Open in documents on the document's menu goes to it. - Beneficial owners of an organisation, with percentages that cannot add up to more than the whole.
- Politically exposed person declarations.
- Source of funds for high risk and high value work.
The risk band
The system suggests a band, low, medium or high, from the kind of client, the kind of matter, the value, the jurisdiction and any PEP declaration. The compliance function confirms it with a reason. Verification is refused until what the rule requires is held.
A verified party is reviewed again after a period set by its band, three, two or one year by default. A document that expires, or a review that falls due, puts the party back on the worklist.
Verifying a party also sets a task, Refresh KYC, due on that day. It goes to the person named under Settings, General, Compliance, KYC refresh goes to; with nobody named, it goes to the firm's only KYC verifier, or stays unassigned for a partner to hand out where several may verify. A new risk band moves the task's date, verifying the party again completes it and sets the next one, and rejecting the record cancels it. Open task, beside the refresh date on the KYC tab, goes to it.
The worklist
Compliance, KYC worklist lists every party missing something, due for review or expired. A party is due for review from 60 days before its refresh date; the firm changes the window under Settings, General, Compliance, Refresh notice (days).
KYC and opening a matter
By default an incomplete KYC warns when a matter opens and leaves a banner on it. The firm can set it to block opening instead.
The banner stands on every tab of every matter the party is a client of, not only the overview, for as long as the matter is being worked on. It names the client and says whether their KYC is missing, not verified yet, lapsed or refused, with a link to their KYC for anyone who may read it. Once KYC is verified, the same banner says when it lapses as soon as the refresh date comes inside the firm's notice window, so it can be refreshed before the matter is left acting on lapsed KYC. A closed, archived or declined matter shows no banner.
Internal concerns
Anyone may raise a concern about suspicious activity. Only the compliance function and the managing partner can read concerns; the person who raised one sees that it was received and nothing more, and a client never sees anything. Concerns are listed under Compliance, Concerns, and Raise a concern on a party's record starts one. The compliance function assesses each concern and records whether an external report was made, with its reference.
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- Open a matterRecord the enquiry, add the client and parties, clear the conflict check and complete the opening checklist, then open the file.
- Run and decide a conflict checkCheck every proposed party against the whole register before a matter opens, and record the partner's decision for good.