Why ICO? Cryptotrend in 2018

An initial coin offering is similar in concept to an initial public offering (IPO), both a process in which companies raise capital, while an ICO is an investment that gives the investor a…

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Know Your Customer Best Practices

Financial institutions have a lengthy list of Anti-Money Laundering compliance requirements. They face a mountain of risks from a large number of financial transactions, each of which can carry significant risks.

AML compliance programs are built on a systematic review of a large number of financial transactions. The focus of this review has to be on triggers that identify suspicious transactions or customers.

Know Your Customer procedures are a critical function to assess and monitor customer risk.

“KYC” refers to the steps taken by a financial institution (or business) to:

A best-practices KYC program will include the following elements:

A CIP is the starting point for any KYC process. In the financial institution context, a best practice is for the relationship manager to initiate the CIP process but coordinate and communicate with the due diligence manager.

In implementing this component, clear, defined process are essential. A consistent method of onboarding third parties indicates that an organization takes KYC seriously. All processes should be thoroughly documented to create a strong audit trail of decisions made. A company should keep an internal database with approved and disapproved third parties, vendors and suppliers to avoid duplication of effort.

At a minimum, due diligence should confirm beneficial owners, sanctions list screening of beneficial owners and relevant entities, politically exposed persons (“PEP”) involvement, and other government database checks.

In determining what level of due diligence is appropriate (CDD v. EDD), a company should look for “red flags” relating to:

EDD steps may include senior management approval, additional due diligence investigations, on-site visits, contractual certifications, third-party audits, source of funds certifications,

Conducting EDD on all customers is burdensome and undermines the purpose of a risk-based AML Program. By nature, some customers will inevitably present lower risks than others.

Best practices for financial institutions include transaction monitoring systems and refreshing due diligence information every six to twelve months.

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