Sanctions screening, AML and beneficial owners

Interactive tutorial

Follow the course step by step in the interactive player.

Lessons

1. 1A tour of the AML/CFT hubThis lesson is for the AML officer and the compliance officer. You will walk through every tab of the AML/CFT hub on a company that has no records yet, so you know what each tab is for, what an empty tab looks like, and where the report and the year filter are, before you start entering anything.6 min
2. 2Check that the sanctions lists are up to dateThis lesson is for the AML officer. Before you rely on any screening result you will check which sanctions lists are loaded, which of them are required, when each was last updated, and what the app does when a list is out of date. In this example every list is current, so the paused state is explained but not shown.5 min
3. 3Screen a new supplier by handThis lesson is for the AML officer. You will check two new suppliers against the sanctions lists before the company trades with them, fill in every field of the Screen Counterparty form, see the country warning, and learn to read a Cleared result in the result box and in the list of checks.6 min
4. 4Review a possible match and clear a false positiveThis lesson is for the AML officer. You will screen a walk-in customer whose name is almost the same as an entry on a sanctions list, read the possible match, compare it with the customer's identity card, look at the Confirm decision without taking it, and clear the check as a false positive with a written reason. The list entry used here is not a real one: it comes from a list called Training examples, fictional, which exists only in this training environment.7 min
5. 5What the accountant's entries send to the AML teamThis lesson is for the accountant, and for the AML officer who wants to know where alerts come from. You will record one purchase and two sales in Tax Intelligence. Nothing on the accountant's screen changes, but behind it every supplier and customer name is screened against the sanctions lists and every amount is tested against the monitoring rules. The next lessons show what the AML team receives.7 min
6. 6A possible match raised by a sale, and assigning the reviewThis lesson is for the AML officer. The accountant has just recorded three transactions. You will see what arrived in AML/CFT without anyone screening by hand: the names in the screening list, a possible match in the Review Queue, a critical alert, and a due diligence record opened automatically. Then you will assign the review to the compliance officer and use the Assigned to me filter.6 min
7. 7Find a review assigned to you and escalate itThis lesson is for the person a sanctions review is assigned to, here the compliance officer. You will find the review in My Actions, open it, use the Assigned to me filter, and escalate the check with a note because it cannot be decided today. You will also see where an escalated check goes and how it is concluded later.6 min
8. 8Find any screening check againThis lesson is for the AML officer and for anyone who has to show an auditor that a name was screened. You will read the summary at the top of the Screening tab, filter the list by status and by year, sort it, hide the side list to make room, and read the Needs Attention counts after the reviews of the earlier lessons.5 min
9. 9Record the business risk assessmentThis lesson is for the AML officer. You will record the company's own money laundering risk assessment: a score from 0 to 100 for each of five areas, the risk factors behind the scores, and the controls that reduce them. The app works out the overall score and level, which then show on the dashboard and in the AML report.6 min
10. 10Add a customer due diligence recordThis lesson is for the AML officer. You will open customer due diligence records, called CDD records, for two customers: the company that paid 126,000 dirhams in cash, and an individual. You will fill in every field of the form, learn what each choice means, and read the notice that says the customer's name is sent to a news search when you save.7 min
11. 11Verify and update a due diligence recordThis lesson is for the AML officer. After checking a customer's documents you will mark the due diligence record as verified, see who verified it and when, and update the record the app opened for the new trade customer. You will also learn what each verification status means and which fields can be changed later.6 min
12. 12Store a customer's identity documentsThis lesson is for the AML officer. You will store a customer's trade licence in its due diligence record, with the document type, number and dates, then open it, download it, and read the access log that records everyone who touched it. These are KYC documents; KYC means know your customer.6 min
13. 13How long identity documents are kept, and deleting oneThis lesson is for the AML officer. A customer has closed his account. You will record the date the relationship ended, see the date on which his documents will be deleted, delete a file that was uploaded twice by giving a reason, and change the number of years documents are kept for this entity.8 min
14. 14Screen for politically exposed personsThis lesson is for the AML officer. A politically exposed person, or PEP, is someone who holds or held a prominent public position, and needs closer checks. You will screen two people connected with a corporate customer. The first comes back with no match. The second matches an entry on the list, and you will read the entry, review it and confirm it. The entry used here is not a real office holder: it comes from a list called Training examples, fictional, which exists only in this training environment.5 min
15. 15Monitoring rules and the monitoring scanThis lesson is for the AML officer. Transaction monitoring tests every recorded transaction against rules and raises an alert when one is met. You will read the three rules every company starts with, open one to see its settings, add a rule of your own that looks for the word cash, run a scan, and switch a rule off and on again.7 min
16. 16Work the alerts and draft a suspicious activity reportThis lesson is for the AML officer. You will work through the four open transaction alerts: open one to read it, investigate it, dismiss the ones that are explained, escalate one, and turn one into a suspicious activity report with a narrative. Then you will find the draft report on the SARs tab and send it for review by a second person.9 min
17. 17Approve a suspicious activity report and record its filingThis lesson is for the second person who reviews a suspicious activity report, here the compliance officer. You will find the report the AML officer sent for review, read it in full, export the list, approve it, download the goAML file, and record the reference once the report has been filed in the regulator's portal. ComplianceOS never files for you: the filing itself is done by a person outside the app.7 min
18. 18Adverse media checks and the switch that controls themThis lesson is for the AML officer. An adverse media check looks for bad news about a customer or supplier. Because the check sends the name outside ComplianceOS, each entity has a switch for it. You will switch the checks off and on to see what changes, run a check on a supplier, read a flagged result, and record your review of it.7 min
19. 19Map relationships and run the network analysisThis lesson is for the AML officer. Money laundering often hides in connections: the same person behind a customer and a supplier, or ownership that runs in a circle. You will record three relationships between parties, read them back, and run the network analysis, which looks for circular ownership, links to politically exposed persons, links to sanctioned parties, and concentration.6 min
20. 20The audit trail, the AML report and the exportsThis lesson is for the AML officer and anyone preparing for an inspection. You will read the audit trail of everything done in the hub, open one entry in full, limit the hub to one financial year, download the AML report, and export the customer due diligence records.6 min
21. 21Record the company's beneficial ownersThis lesson is for the compliance officer, who keeps the register of beneficial owners. An ultimate beneficial owner, or UBO, is a real person who owns or controls 25 percent or more of the company, or controls it in another way. You will add three owners, filling in every field of the form: two shareholders, and one person who holds no shares but has the right to appoint the directors.8 min
22. 22Record a change of ownership and read the change logThis lesson is for the compliance officer. One owner has sold 10 percent of the company to another. You will lower the seller's share, raise the buyer's, attach the share transfer agreement as proof, and read the change log, which records who changed what, from which value to which, and the deadline for filing the change.7 min
23. 23Remove an owner, and restore one removed by mistakeThis lesson is for the compliance officer. A person's control over the company has ended, so you will remove her from the register with the date it ended and a reason. You will see where removed owners are kept, find the removal in the change log, and then restore her, as you would after a removal made by mistake.7 min
24. 24Indirect ownership and the ownership chainThis lesson is for the compliance officer. Owners do not always hold their shares in their own name. You will record that one owner now holds her shares through a holding company, read the Ownership Chain view, which shows how many levels lie between the owners and the company, and record ownership links for the group view, called Effective Group Ownership.7 min
25. 25Record the filing, the annual confirmation, and download the declarationThis lesson is for the compliance officer. Changes to the register must be filed with the registrar, and the register must be confirmed once a year. ComplianceOS does not submit anything to the registrar: you file outside the app and then record the reference here. You will record a filing, record the annual confirmation, and download the PDF declaration of beneficial owners.7 min
26. 26The beneficial owner register for the AML officerThis lesson is for the AML officer. Beneficial owners are screened as part of AML work, so this role can read the register, export it and screen the owners again, but cannot change who the owners are. You will see what the register looks like with this role, screen one owner and then all owners again, find those checks on the Screening tab, and download the declaration.6 min
27. 27What an auditor sees: read-only accessThis lesson is for auditors and for anyone who needs to know what a person without the right permission sees. The auditor role can read AML/CFT and the beneficial owner register and download from them, but cannot change anything. You will go through the hub with this role and see which buttons are grey, what they say when you point at them, and what still works.6 min
28. 28How this connects to the rest of ComplianceOSThis closing lesson is for everyone who took the course. Signed in as the compliance officer, who can see every module, you will follow one sale from the accountant's screen through sanctions screening, the alert, the due diligence record, My Actions and the risk register, conclude the escalated check by confirming the match and watch its risk change, look at the evidence vault, and see where the owners in the UBO Register and the customers' documents fit in.10 min

How this connects to the rest of ComplianceOS

• Tax Intelligence

  The supplier or customer name on every transaction the accountant saves is screened against the sanctions lists, and the amount is tested against the monitoring rules. Alerts and checks appear in AML/CFT without anyone in the AML team acting.

• Customer due diligence

  A possible sanctions match on a name from another module opens an enhanced due diligence record and a critical alert automatically.

• My Actions

  A sanctions review assigned to you appears in your My Actions list, with a button that opens the Screening tab.

• Risk Register

  Sync Modules, or the overnight sync, imports every pending, escalated or confirmed sanctions check as a risk with the source Sanctions, and closes it once the check is cleared.

• Evidence Vault

  Review decisions on screening checks, and changes to due diligence records and reports, are stored automatically as sealed evidence under the five year AML retention policy.

• UBO Register

  Beneficial owners are screened against the same lists when they are added and when the AML officer screens them again; each screen is a check on the Screening tab.