1 / 13

The role of the KYC researcher

The role of the KYC researcher. Michele Bate Archer Van Den Broeck Limited. Five questions…. What is Know Your Customer research? Why carry out KYC research? What information are we looking for? Where do we find it? What are some of the pitfalls and problems involved?.

avi
Download Presentation

The role of the KYC researcher

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. The role of the KYC researcher Michele Bate Archer Van Den Broeck Limited Archer Van DenBroeck

  2. Five questions… • What is Know Your Customer research? • Why carry out KYC research? • What information are we looking for? • Where do we find it? • What are some of the pitfalls and problems involved? Archer Van DenBroeck

  3. What is KYC research? • A form of due diligence which asks the question: “Is my reputation likely to be damaged by doing business with this company or individual?” • Part of a risk-based approach, taking into account: • The country in which the client is based • The nature of the company’s business • The type of account/banking product to be opened • The anticipated volume/value of transactions • Politically exposed persons - high profile scandals involving money laundering by high-ranking officials Archer Van DenBroeck

  4. Who is doing KYC research? • Financial institutions: credit institutions, banks, investment managers, money service businesses (including bureaux de change), insurance companies • Professional services firms: accountants, auditors, tax advisers, insolvency practitioners, legal firms • Trust and company service providers • Estate agencies • Auctioneers • Casinos • Corporations, e.g. exporters Archer Van DenBroeck

  5. Why do companies do KYC research? • Because they have to! • Compliance is a legal requirement in most jurisdictions and has become more stringent in the wake of 9/11 and Enron: • USA Patriot Act 2001 • EU Money Laundering Directives • UK Money Laundering Directives • Reputational risk is now recognised as important in its own right - not just financial risk and fear of legal or regulatory sanctions Archer Van DenBroeck

  6. When should KYC research be carried out? • New customers – account opening • Existing customers – filling information gaps • Ongoing requirement – monitoring of transactions Archer Van DenBroeck

  7. What information are we looking for? - individuals • Verification of identity • Confirmation of information provided • How have they acquired their wealth? • Links to organised crime – money laundering? Terrorism funding? • Political affiliations and exposure - corruption? • Corporate affiliations – bankrupt companies? Fraud? Undesirable associates? • Bankruptcy, disqualification from being a director, criminal convictions, civil litigation • Regulatory issues Archer Van DenBroeck

  8. What information are we looking for? - companies • Confirmation of information provided • Identification of beneficial ownership - who is actually behind the company? Who controls it? • Links to organised crime – money laundering? Terrorism funding? • Political affiliations and exposure - corruption? • Corporate affiliations – bankrupt companies? Fraud? • Litigation • Regulatory issues • Environmental issues • Health and safety issues • Social concerns Archer Van DenBroeck

  9. Where do we find it? • Personal information: • Land Registry • Electoral roll • Professional associations • Corporate affiliations: • Companies House • ICC shareholder reports • Dun & Bradstreet Global Reference Solution • Bureau van Dijk Archer Van DenBroeck

  10. Where do we find it? • Press archives • Factiva • Lexis-Nexis • Dialog • Internet: • Newsgroups • Blogs • Litigation indices: • Lexis-Nexis • BIALII Archer Van DenBroeck

  11. Where do we find it? • Bankruptcy: • Individual Insolvency Service • Watch lists: • Lexis-Nexis • Complinet • Office of Foreign Assets Control (OFAC) • United Nations • Bank of England • World Bank list of ineligible firms for procurement Archer Van DenBroeck

  12. Pitfalls and problems • “Box ticking” mentality • Incomplete/out-of-date information, especially in some jurisdictions • Budgetary constraints • Not having the complete picture • Have I got the right company/person? Archer Van DenBroeck

  13. Sources • Land Registry: www.landregistryonline.gov.uk • Companies House: www.companies-house.gov.uk • Electoral roll: www.192.com • Newsgroups: http://groups.google.com • Blogs: http://blogsearch.google.com/?tab=gb&q= • BIALII: www.bailii.org/form/search_cases.html • Individual Insolvency Service: www.insolvency.gov.uk/eiir • OFAC SDNs and blocked persons list: http://www.treas.gov/offices/enforcement/ofac/sdn/t11sdn.pdf • United Nationsl blacklist: http://www.un.org/Docs/sc/committees/1267/pdflist.pdf • Bank of England sanctions list: http://www.bankofengland.co.uk/publications/financialsanctions/sanctionsconlist.htm • World Bank listing of ineligible firms: http://web.worldbank.org/external/default/main?theSitePK=84266&contentMDK=64069844&menuPK=116730&pagePK=64148989&piPK=64148984 Archer Van DenBroeck

More Related