How robust are your client onboarding procedures?
AML checks are only one element of the customer onboarding process. For example, Failure to ensure that:
- A client’s regulatory classification is correct and up to date
- The correct documentation has been sent to the client and, if required, has been returned properly executed
- The records reflect the permitted business for the client including authorities and limits and that these are communicated to all relevant parties
can lead to significant regulatory penalties and substantial commercial damage to your Firm.
We can help you to navigate the pitfalls of client onboarding
Our experienced practitioners have dealt with all aspects of client onboarding and have considerable knowledge of the pitfalls when onboarding new clients or reviewing existing ones. We can readily identify the risks that your Firm faces and identify the steps that you need to take to address those risks.
Our Client onboarding reviews include:
- A full review of your client onboarding and client classification procedures, making recommendations as necessary
- Using your procedures or any revised procedures, our consultants will undertake past business reviews of your client files to check for gaps and recommended remediation steps
- Checking that your client documentation and consents are complete with a full audit trail
- Reviewing the adequacy of the process for cases in which a third party is used for onboarding, giving assurance to your senior management that the process works in practice; and
- Providing training on your onboarding policies at all levels throughout your Firm, ensuring a clear understanding of the procedural steps.