Know Your Customer & Customer Due Diligence Rule Program Advisory

 
 

Addition of a new, 5th Anti-Money Laundering (AML) Program Pillar: Customer Due Diligence (CDD):

  1. Logical, Structured, Disciplined and Systematic

  2. Sustainable & Repeatable

  3. Experience and Expertise

  4. Objective and Independent

  5. Focused on the CDD rule’s impact on AML transactions monitoring

  6. As part of the CDD Rule Element #3, we help our clients understand the nature & purpose of customer relationships in order to enable them to enhance their customer risk profiles by expanding their methodology for KYC Customer Risk Scoring. This step satisfies the CDD Rule’s following requirements:

>  CDD Rule Element # 3:  Understanding the nature and purpose of customer relationships to develop a customer risk profile; and

>  CDD Rule Element #4 on-going monitoring for reporting suspicious transactions and, on a risk basis, maintaining and updating customer information

  1. Proven Risk-Based & Sustainable Program Building, Enhancement & Testing Methodology, Process and supporting automated Tools.

  2. Validates Alignment and Conformance with AML Risk Assessment  & CDD Risk Triggers, Applicable Local, Regional & Group Level Rules, Regulations, Policies & Procedures

  3. Expertly Documented Current Program State & Status, Controls, GAPs and Associated Risks,  Notes Continuous Improvement Roadmap, Recommended Changes and Remediation Steps

Vesta LLC and its team of CDD Rule professionals highlight the Rule’s impact on your institutions AML Program. As part of our CDD Rule services, we help our covered clients to incorporate the 3rd & 4th CDD Rule Elements into their Enterprise-Level AML Program in the following manner:                           

  1. Work with our covered clients to enhance their AML program by the addition of a 5th, new Program Pillar. This pillar specifically requires appropriate risk-based procedures for conducting ongoing CDD.                                                                                                                  

    1. As part of CDD Rule Element #3, we help our clients understand the nature & purpose of Customer Relationships to enable them to enhance their Customer Risk Profiles by expanding their KYC Customer Risk Scoring Model – Methodology , incorporating newly sourced Beneficial Ownership information. This step satisfies the requirements related to CDD Rule Element # 3: Understanding the nature and purpose of customer relationships to develop a customer risk profile; and  #4: ongoing monitoring for reporting suspicious transactions and, on a risk basis, maintaining and updating customer information.                  

    2. As part of CDD Rule Element #4, we help our clients enhance  their AML Transactions Monitoring Program, specifically, their AML Transactions Monitoring Coverage. including, but not limited to, enhancements to their current Customer Population Segmentation Model, Alert Risk Scoring Rules and the various Detection Scenarios, Models &  Rules they are currently running. This is accomplished by incorporating and leveraging the expanded Customer Risk information & enhanced Customer Risk Profile into their Monitoring coverage, ensuring that the coverage is risk-based & aligned with their organization’s AML Risk Assessment. These steps satisfy the requirements related to CDD Rule, Element #4:  Ongoing monitoring for reporting suspicious transactions and, on a risk basis, maintaining and updating.