Background:

Using the person resource, a merchant can conduct searches against PEP and sanction lists during for example an onboarding process, giving the Merchant good understanding of the person at that exact time.

But if the person in question becomes a PEP or gets sanctioned after becoming a customer, companies under AML legislation are required to discover this and start treating that customer accordingly. For sanction lists there is a need to be up to date every time a new sanction list is published. Finding out if a person has become a PEP, has married a PEP or has become a close associate with a PEP can be even more cumbersome.

The continuous screening service has been offered to help merchants keep up to date with the sanction and pep lists in a practical manner.

How does the Continuous screening service work?

To make use of the service, the merchant needs to upload his entire list of persons to be screened. This might include both direct customer and even persons that have a relevant role in a company that is a customer (for example beneficial owners or a CEO). The merchant will be notified if there is a match between any of the persons in the customer list against the relevant PEP and sanctions lists.

If the persons on the customer list are matched against the PEP and sanctions lists at a later point, the Merchant will receive an alert so that the compliance staff can act on this information.

The merchant can add more people to the list screening when they onboard new customers.

Intended use

The Continuous screening service is intended for use in the ongoing customer due diligence process (CDD), after the customer is already onboard and has been through an initial customer due diligence process.

It is not recommended for use to initially screen the customer. The reason for this is that there is a delay. The person resource gives immediate feedback about the screening results, while the Continuous screening service has potentially a delay of a day or two before the Merchant can complete the CDD, onboard the customer and get them started.

Some merchants consider skipping the initial step and not do any CDD while onboarding the customer, and only rely on the ongoing due diligence process. This is not recommended since it might let unscreened persons that are on PEP and sanction lists abuse the customer relationship for money laundering or terror financing purposes before getting discovered and stopped. The legislation clearly expects CDD before letting the customer getting started, and even though there are some exceptions, the Merchant should consider such a strategy carefully and document their risk based reflections about it.

The recommended use is to use the person resource for initial CDD and the Continous screening for ongoing CDD.

GDPR notice

Use of the service implies some minimal information about your customers to be registered for the service to work. The name and birth date of the relevant persons will be stored, and used for matching. The matches themselves however is not stored on our side, but only passed on to the Merchant, following a Privacy by Design methodology.

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