A WORK AND CONTROL TOOL
The module CONCEPT Compliance LBA-AML is a tool designed to allow you to collect all the information in order to satisfy all new compliance requirements (fight against money laundering “AML”), including the requirements for 2016 (AMLO-FINMA-2016) as well as tax compliance and monitoring of transactions at risk.
It is also a fast and efficient control tool for the Compliance Officer through its diagnostic modules and risk assessment LBA-AML. It allows in particular controlling the adequacy with the legal requirements, facilitating the rapid appreciation of the good recording of customer records and highlights the missing documents and those periodically expired.
Finally, it is a decision support tool for the governing bodies (Executive Committee & Board of Directors).
A CRM (Client Relationship Management)
It is, in fact, a CRM Module (Client Relationship Management) for managing :
1) PROSPECTS facilitating controls prior to the client/co-contractor acceptance.
2) CLIENTS / CO-CONTRACTORS, allowing, on the basis of compliance documentation, collection, capture, then archiving of all information.
It thus gives the people responsible (internal controller / external controller) the possibility of quick checks.
AN INTEGRATED PRODUCT & INTEGRABLE
It can be used independently or integrated with CONCEPT products :
- CONCEPT Family Office versions Multi Family(MFO) and Single Family (SFO)
- CONCEPT Independent Asset Managers versions “Single” or “Multi databases “, Platform facilitating the grouping of independent asset managers
- CONCEPT TrusteeTM
- CONCEPT Processus (Bank interfaces : 30 banks or bank software already interfaced, bringing significant productivity gains)
Interfacing with other Asset Management software is possible insofar as the change of the existing system is not desired.
A FLEXIBLE PRODUCT
Apart from the modules included in the base product, it is possible to add, at any time, optional modules such as those described on page 1, and in particular :
- Compliance diagnostic (detection of anomalies such as missing data, control of maturity dates etc.)
- Risk estimation (LBA/AML) :
- Country risk
- Determination of increased risks
- Identification of complex structures (organisation chart)
- Audit trail
- Identification criteria of FATCA US & other legislation (CRS)
A TOOL FOR ANALYSIS AND RISK MANAGEMENT LBA – AML
CONCEPT Compliance LBA-AML also allows quantifying various risks, more specifically: :
1) COUNTRY risk :
- This module allows determining risk assessment of each country on the basis of evaluation criteria specific to each company, such as:
- List of exclusions FATF, SECO etc.
- List of member countries of the OECD / FATF
- List of countries EAR (TIEAs) having signed agreements on the exchange of information in tax matters and their probable date of entry into force
- List of countries Corruption Perception Index (CPI index)
Based on this information, management can thus propose a risk rating countries for ratification by the Board of Directors.
It is then possible to create a
- Internal list of authorized and prohibited countries
2) The determination of increased risk on the basis of criteria, such as :
- Country rating (LBA/AML) (used in the context of nationalities, domiciles, headquarters … see above)
- Involvement of PEP or people close to a PEP
- Involvement of domicile companies
- Transactions Compliance , involving a manual or automatic input (via the module CONCEPT Processus +depending of the volume to process providing significant productivity gain)
- Detection of complex structures (with automatic generation of a hierarchical and functional organization chart)
A TOOL REPRODUCING A WORK PROCESS
As all our software, CONCEPT Compliance LBA-AML, is the expression of a computerized work processes, increasing the productivity and facilitating a rapid access to data as well as documents (can be interfaced with electronic document management software of your choice (DMS)).
The information input process regarding prospects and then clients / co-contractors is based on the different forms, required by the supervisory authorities and / or self-regulatory organizations, such as:
1) Form for a new business relationship
2) Contract of mandate
3) Forms describing the business relationship:
- Identification of the person who initiates the business relationship (Introducer)
- Identification of the client / co-contractor
- Identification of the beneficial owners:
- For a legal persons (entities) without any beneficial owners identified:
- Identification of the controlling holder (Shareholder(s) holding more than 25 % of the share capital or member of the management organs )
- Identification of managements organs / board of directors
- For a trust:
- Identification of the Trustee
- Identification of the Settlor, Protector, etc.
- Identification of the beneficiaries (if defined)
- For a trust:
4) Form describing the circumstances of the establishment of the business relationship
5) Form describing the economic background:
- Bank relationships
- Origin of funds
- Initial amount of assets
- Expected evolution of assets
- Identification of power of attorney
6) Identification of stakeholders related to the client / co-contractor (Proxies, Trustee, Advisors etc.)
7) Historic of the business relationship, other developments of the relationship
8) Journal of transactions (Transactions compliance)