AML AcCounting practice Records


Using the AML Accounting Practice Records

  • This tool is meant to complement your current AML programme by creating a central cloud-based record of CDD, Ongoing Monitoring, Active Enquiries, Report Submissions if required e.g. when forming a company, authorising funds for payroll and doing a share transfer.

Customer Due Diligence (CDD)

  • When you have identified that CDD is to be completed on a client, create a Customer Due Diligence record and follow the steps.


Identification Verification (IDV)

  • For every "beneficial owner, effective controller or agent acting on behalf of" the client, you will need to verify their identity. Create and Identification Verification record for each of these people.

  • Examples of people you may need to IDV are:

    • Directors​

    • Shareholders

    • Spouses

    • Trustees

    • Beneficiaries

    • Power of Attorneys

    • Solicitors

    • Partners

    • Office holders

    • Managers

  • There are four methods of IDV to choose from:

    • Sight their ID in person and verify true likeness then take a copy for records​

    • Obtain a certified copy of their ID

    • Use Electronic IDV such as 2Shakes

    • Reliance on third party (e.g. if a lawyer has already conducted CDD)

  • If the Certified Copy option is chosen, you can choose to generate some correspondence to send to your client explaining what is required (who they can get to certify the copies).

  • Letter from government agency - you may already have something on file or access to an IRD letter for your client.  If not, ask them to supply this.

Enhanced Customer Due Diligence

  • In most cases, you will need to conduct standard customer due diligence, however in certain circumstances the tool will prompt you to conduce EDD which includes verifying their source of wealth and/or source of funds. This is called Enhanced Customer Due Diligence.

  • If the client is a Trust, you will need to perform EDD. There are exceptions around the info required for certain Trusts (refer to the steps in the tool). 


Ongoing Monitoring

  • ​You are required to monitor your client in regards to the captured service you are providing. If it is a one-off activity (such as forming a company), then no monitoring is required. However if you do form more companies for this client in the future, you should consider recording this in the Ongoing Monitoring log.

  • Create an Ongoing Monitoring record to record observation notes or any required actions if you are regularly monitoring the client.

  • Do not conclude each Ongoing Monitoring record until the end of the reporting period (30 June). This will allow you to keep adding entries as needed.

Active Enquiries

  • An Active Enquiry is used to investigate unusual transactions or activity of concern. It will either result in no suspicion being formed, or a suspicion being formed therefore a Suspicious Activity Report (SAR) to be submitted to the FIU.

  • If required, create and Active Enquiry investigation and follow the steps in the form in order to arrive at your conclusion.

Report Log

  • There are two types of reports that may be submitted to the FIU

    • Suspicious Activity Report (SAR) - If the outcome of your active enquiry is the submission of an SAR, create an SAR record and enter the information required (as per the steps).​

    • Prescribed Transaction Report (PTR) - If a transaction is conducted which requires the filing of a PTR, create a PTR record and enter the information required (as per the steps).

  • Do not conclude each Report Log until the end of the reporting period (30 June). This will allow you to keep adding entries as needed.

Annual Rollover

  • At the end of every reporting period 30 June, conclude the AML Accounting Practice Record job and then rollover.

  • The job will reset for the current period and you can delete any records from the prior year that aren't required for the current year. For example, if you created a Customer Due Diligence record for a client when forming a company - as this is a one-off activity and the record of the CDD is kept in the prior year's file (indexed on left-hand side menu bar), you can delete the record from the current job.

  • For records you would like to keep in the current year, you can click into these and bring forward prior year's answers (or ignore and create a new answer).




Customer Due Diligence