Within this section you will find links to forms, checklists etc that may be helpful. Feel free to use as inspiration for creating your own templates.
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CLIENT DUE DILIGENCE (CDD)
CDD – POLICY / STANDARDS
Enables organisation’s CDD policy to be presented in a matrix style rather than a purely narrative style
STEP 1: For the primary party (i.e. the immediate client), obtain info/evidence for all fact types marked ‘Yes’ in ‘Primary’ column next to relevant entity type/individual
- Primary Party acting as TRUSTEE? Trust itself treated as primary party instead + Trustee treated as controller under Step 3
- Multiple Primary Parties (e.g. joint account)? Repeat Step 1 for each such party
STEP 2: This step ONLY required if primary party is an entity. For each relevant owner, obtain info/evidence for all fact types marked ‘Yes’ in ‘Owner’ column next to relevant entity type/individual
- Owner acting as TRUSTEE? Trust itself treated as owner instead + Trustee treated as controller under Step 3
- Owner an ENTITY (e.g. company, partnership, trust)? Repeat Step 2 for each such entity peeling back layers until reach individuals
STEP 3: For each relevant controller, obtain info/evidence for all fact types marked ‘Yes’ in ‘Controller’ column next to relevant entity type/individual
- Controller an ENTITY (e.g. company, partnership, trust)? Repeat Step 3 for each such entity peeling back layers until reach individuals
CDD – ORG CHART
Enables ownership/control structure of client to be presented in a horizontal org chart style
- Uses a ‘space saving’ format which resembles a table with positioning of boxes used to convey relationships between tiers
- Portrait: 2 tiers – space for 10*1st level owners/controllers
- Landscape: 3 tiers – space for 4*1st level owners/controllers
A separate chart should be completed for ownership structure and control structure if necessary
CDD – FACTFIND
Enables facts about any party (whether primary, owner or controller and regardless of entity type/individual) to be recorded together with evidence of such facts
- The ‘Role’ column indicates for which parties each fact is required – some facts are relevant for the primary party, but not owners and/or controllers
- Where practical, policy has been reflected in the Factfind to avoid the need to refer back to Policy when completing
- TO FLAG ANY INFO AS A POTENTIAL RISK/CONCERN/ISSUE – ADD ! ANYWHERE IN CELL – THE CELL WILL TURN RED
A separate form should be completed for each individual/entity
SUSPICIOUS ACTIVITY REPORTING (SAR)
SAR – LOG
Enables key SAR details to be recorded to facilitate tracking of individual SARs through the stages of the internal submission, evaluation/decision process and the external submission process and facilitates analysis of such details
SAR – INTERNAL SAR
Enables details regarding subjects, relationship with the organisation and the reason for disclosure to be recorded
SAR – EVALUATION
Facilitates evaluation of completeness and the decision to disclose and/or seek consent