Lesson 10 of 26

A possible sanctions match goes to the MLRO

For: AML officerAbout 7 min

What you will be able to do

This lesson is for the AML officer, who is also the money laundering reporting officer, the MLRO. When a screening finds a possible match on a sanctions list, an agent never clears or confirms it: the decision is the MLRO's. You will ask Nasser to screen a new freight supplier, answer its question about who decides, and see the match assigned to you.

Before you start

  • You are signed in as the AML officer of Meridian Souq Trading LLC.
  • Zephyrline Maritime Holdings FZE is a fictional supplier whose name is close to an entry on the training sanctions list.

Steps

  1. 1

    Ask Nasser to screen the supplier

    In the AI team's Chat for Meridian Souq Trading LLC, type @ and pick Nasser, and type: we want to start using Zephyrline Maritime Holdings FZE as a freight supplier for our imports from China. Please run the due diligence and screening on them before we sign.

    • Type Message to the AI team: @Nas
    • Choose NNasserAIFinancial crime
    • Type Message to the AI team: @Nasser we want to start using Zephyrline Maritime Holdings FZE as a f…
  2. 2

    Select Send

    Select Send. Nasser's card under your message is marked Working.

    • Select Send
  3. 3

    Follow Nasser's to-do list

    Nasser writes a to-do list of five items: open a due-diligence record for Zephyrline, screen it against the sanctions lists, review the adverse-media result, screen its owners and directors, and hand over what is still needed before signing. The line Now: says it is screening the name against the sanctions lists.

    The screen at step 3: Follow Nasser's to-do list
  4. 4

    Answer Nasser's question and go-ahead

    The screening finds a possible match, and Nasser does not decide it. It asks two things in one message: who the MLRO is, because no MLRO is recorded in the AML settings and the check must go to that person, offering the people who could be; and who owns and runs Zephyrline. Type your answer in the box under the question: you are the MLRO, so assign it to you. Select Send. Nasser keeps the answer as a fact about the company, so it won't ask again. Then a go-ahead follows: to note the match on the supplier's due-diligence record and raise it to very high risk and enhanced due diligence. Read it and select Approve.

    • Type Your answer: I'm the MLRO - assign it to me (Hamad Ali).
    • Select Send
    • Select Approve
  5. 5

    Read Nasser's answer

    Nasser's green Answer starts: please don't sign with Zephyrline yet. The name matched a listed entity exactly; Nasser gives the listed names and the list date, and points out that the list source shows as Training, for you to check before you decide. The check is assigned to you and still pending: Nasser neither cleared nor confirmed it. Adverse media is clear, the due-diligence record is at very high risk, and the owners still need screening once you have their names.

  6. 6

    Find the match in AML/CFT

    In the left menu, under Financial crime, open AML/CFT and its Screening tab. The screening of Zephyrline Maritime Holdings FZE is there as a possible match, assigned to you. You decide it here.

How to check it worked

Nasser's green Answer says the screening found a possible match, that it did not clear or confirm it, and that the check is assigned to you. Sanctions shows the screening waiting for your decision.

Common mistakes

  • Expecting the agent to decide the match. Clearing or confirming a match is the MLRO's decision.
  • Signing with the supplier while the match is open. Decide the match first.
  • Answering "who is the MLRO" each time. Once you answer, the agents keep it as a fact about the company and don't ask again.

Check your understanding

  1. 1. A screening returns a possible match. What does Nasser do?

    1. A.Clears it if the score is low
    2. B.Assigns the check to the MLRO with the evidence, without deciding
    3. C.Confirms it and blocks the supplier
    4. D.Deletes the screening
    Show answer

    Answer: B. Assigns the check to the MLRO with the evidence, without deciding

    Possible matches are decided by a person; the agent gathers the evidence and passes it on.

  2. 2. You tell Nasser who the MLRO is. What happens next time?

    1. A.It asks again
    2. B.It remembers it as a fact about the company
    3. C.It asks the administrator
    4. D.It guesses
    Show answer

    Answer: B. It remembers it as a fact about the company

    A lasting fact you give is kept as knowledge for the agents on that company.