Law firms have been responsible for compliance since the Proceeds of Crime Act 2002 and more recently the Money Laundering Regulations 2007. Sysero’s workflow and forms tools can be used to design custom compliance procedures.

 

KYC involves a number of processes that need to be managed:

Collection of client information

• Firms need to decide how much data they need to collect on each client. This needs to vary acording to the risk profile of the client
• Identify the type of client- legal entity or person
• Provide fields to enter the Client name, address and other contact details
• Define the internal team including Matter Manager, Client Partner, MLRO and additional escalators if needed
• Collect client risk assessment information including country, referrer and type of business
• Connect record to existing client number for existing matters

 

Internal conflicts checks

• Collect the details on the checks
• Record any links to checking data and documents

 

Collection of information on the benefical owners

• Define each BO and collect relevant information
• Store any ID documentation

 

Checking against registries

• Companies house, BVD, Yellow pages, Google..

 

Checking for sanctions

• EU Sanctions list
• Need to re-check all live clients every 24 hours

 

Risk assessment, escalations, decisions and declarations

• Collect declarations for each BO.
• Do not allow the process to complete without each member of the team completing declarations that they have completed their obligations

 

Creation of Client/Matter number and DM Workspaces

• If successful - create working environment and copy over any documents collected as part of the compliance process

 

Creation of engagement letter

• Ideally use the compliance information to create customised engement letters