CurrencyXchanger ManualsCurrencyXchanger 4 User Manual Customers ModuleWhen a Customer's Name Matches the Sanction List

When a Customer's Name Matches the Sanction List

How to document true or false matches on a sanction list

Once your 'Compliance Warnings' in your 'Server Preferences' are set up

Every time you enter a new customer's information, they will be checked against the sanction lists and you will be warned as per your 'Server Preference' set up under the 'Compliance Warnings' tab.

If there is a match you will be directed to a warning pop up where you will have to do your due diligence to decide whether there is a true match or a false match (false positive).

 

Once your 'Compliance Warnings' in your 'Server Preferences' are set up

Sanction List Match

  • Once you hit <Tab> after entering the customer's First and Last names, if the name matches a name on any of the sanctions lists you have checked in your User Preferences, a warning will automatically pop up and the customer's account will be placed on hold.
  • The warning window will show a list of names and other aliases the client entered may go by.
  • It will also show the type of warning and the specific sanction list the name was found on.
  • In this case the name typed produced an AML WARNING matched with a name on the OFAC list.
  • As you scroll down it will show you further information about the match such as Date of Birth, Place of Birth, Citizenship, Address etc. you can check against.
  • Hit 'Okay'.
Sanction List Match

Second Warning Pop Up

  • If you see another pop up warning window this is because the name matches another sanction list.
  • Likewise, it will show the type of warning and the specific sanction list the name was found on.
  • In this case the name typed produced an AML WARNING matched with a name on the OSFI list.
  • You can scroll down here as well to see further information about the match such as Date of Birth, Place of Birth, Nationality, Address etc. you can check against.
  • Hit 'Okay'.
Second Warning Pop Up

Account Automatically Placed on Hold

  • Notice once you have hit 'Okay' in the warning windows, the customer's account is now automatically placed 'On Hold' and the customer is now recognized in the system as a high risk customer.
  • Click on the 'Risk Evaluation' tab in order to further your due diligence.
Account Automatically Placed on Hold

Due Diligence

  • Notice the information in the warning pop ups has been populated under the 'Sanctions list check log' with the previous warnings so you can easily reference them.
  • You may wish to check their ID, address, etc to determine whether this is a false or positive match.
Due Diligence

False Positive Match

If you check the customer's IDs and find important information does not match the person in the sanction list, and conclude that this is a false positive match:

  • Check 'Match is false positive'  
  • Uncheck 'Customer is Suspicious'
  • Uncheck 'On Hold' at the top of the screen
False Positive Match

Reason

  • Once you uncheck the 'On Hold' button at the top of the screen, a pop up window will appear asking you for the reason you are removing this customer from a hold when he has appeared on a sanction list.
  • Enter the reason you decided to take the customer off hold and click 'Save'.
Reason

Additional Due Diligence

  • Enter as much information as you can about the customer under 'Risk Analysis and Due Diligence'.
  • The more information you have on a customer the better you can evaluate their risk. Take your time to enter as much information as possible about why you think this customer is not the same person on the sanction list.
Additional Due Diligence

Changing Risk Index and Rating a Customer's Risk Level

  • You may rate and change the 'Customer Risk Index' by dragging the bar along the different risk measurements.
  • The system had automatically placed the customer on a high risk level (of 5) since the customer matched a name on the sanction list.
  • You may wish to leave the risk rate at 'Medium Risk' since you have done your due diligence, however you may not wish to place the customer at a very low risk level since their name still matched a name on a sanction list.
Changing Risk Index and Rating a Customer's Risk Level

Internal Information

  • You may add more internal information by clicking on the 'More Info' tab under 'Confidential Notes' .
  • You will notice that the 'Reason' you previously entered is kept on record and appears here as well.
Internal Information

Sanction List Similar Name

  • Note that if you type a similar name to the name that is on a sanction list, you will also be directed to a warning pop up where it is certainly a good idea to go through the previous investigations and further due diligence in the same manner you would if the name were an exact match.
  • The pop up will show you that the name is not an exact match, yet it is similar - 'No Exact Match! Similar Names Found'.
Sanction List Similar Name

0 Comments

Add your comment

E-Mail me when someone replies to this comment