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Introduction of Automated/Online Client Onboarding and AML/CFT Policy -…
Introduction of Automated/Online Client Onboarding and AML/CFT Policy
Why do we need it?
Regulatory compliance
Adhoc implementation currently
Manage risk
Reduce time & cost & to speed up a mandatory process
Consistency across offices
Already standardised, just needs simpler/quicker delivery
How will it impact clients?
Faster onboarding
Client perceives quick contact/turnaround
Client understands terms of engagement at outset
Online documentation sent/saved to client CRM file
Generally positively
Firm meets its regulatory obligations to clients in sending out client care documentation
AML/CFT onboarding risk undertaken upfront
Increased business benefits
Meet compliance obligations
Standardised process
Save employee cost
Reduces risk of unintentionally taking on high-risk clients
Get a non-fee earning job done quicker
Gets a mandatory/standardised job done without having to constantly have someone else check compliance obligations met
Financial cost to design & implement?
Who will manage process?
Can existing programmes be utilised to create online forms?
Who will investigate other programme platforms and privacy risks
Will the online process save time and money?
How will forms be sent externally and received internally and stored?
Who will create online forms question flows?
Update AL/CFT policy manuals to incorporate new procedures
Training to introduce new process
Privacy or other regulatory issues?
A very real concern
Is security on existing client Email/CRM programme satisfactory?
Privacy policy to be updated (length of storage and useage of information)
Will an automated process meet Dept. Internal Affairs AML/CFT regulation?
Jurisdiction of information storage
Will online process meet Law Society regulatory requirements?
Jurisdiction of information being processed in first place
What if retain status quo?
Increases risk of non-compliance
Potential to cement culture of no-change
Misses opportunity to use existing technology
If existing paid technology is exploited then doubling up
Back office time and costs too high for non-fee earning job
Staff tied up on mandatory compliance is inefficient
Processes are already standardised but inefficient
Staff concerns and training?
What training may be needed?
Guideline of process to be drafted
Will it impact on existing staffing levels?
Can templates be set up to alleviate anxiety about new technology?
Will staff resist or simply not follow the new system?
Will job roles need to be changed around?
Will it increase capacity?
What type of programmes might be used?
Google Forms? (free)
Office 365 Forms? (paid in existing subscription)
Free or paid?
123forms (new platform + paid + jurisdiction re storage of private information issues)
Privacy issues with any platforms??
Other