Understanding KYC monitoring is crucial for businesses and organizations that deal with financial transactions, as it helps prevent money laundering and terrorist financing.
KYC stands for Know Your Customer, which involves verifying the identity of customers to ensure they are legitimate and not involved in illicit activities.
This process is not only important for regulatory compliance but also helps build trust with customers by ensuring their information is secure and protected.
In fact, according to the article, "KYC monitoring can help reduce the risk of money laundering by up to 90%."
What Is KYC?
Know Your Customer (KYC) is a critical function to assess customer risk and a legal requirement to comply with Anti-Money Laundering (AML) laws. Effective KYC involves knowing a customer's identity, their financial activities, and the risk they pose.
KYC procedures are a must for financial institutions to protect themselves from fraud and losses resulting from illegal funds and transactions. This is because helping enable money laundering or terrorist financing can lead to fines, sanctions, and reputational damage.
To establish an effective KYC program, you need to:
- Establish customer identity
- Understand the nature of the customer's activities
- Assess money laundering risks associated with that customer
The primary goal of KYC is to satisfy that the source of the customer's funds is legitimate. This is a fundamental practice to protect your organization from fraud and losses.
Compliance
Compliance is a critical aspect of KYC monitoring, and it's essential to understand the rules and regulations that govern it. FINRA Rule 2090 requires broker-dealers to use reasonable diligence when opening and maintaining client accounts and to know and keep records on the profile of each customer.
The U.S. Financial Crimes Enforcement Network (FinCEN) requires both customers and financial institutions to comply with KYC standards to prevent illegal activity, specifically money laundering. AML, anti-money laundering, is a term for the range of measures and processes used to achieve regulatory compliance.
To maintain ongoing compliance, firms need to conduct regular checks and maintain a detailed audit trail. Consistency is key, so schedule regular checks to ensure you're meeting the regulatory requirements and reducing the risk of financial crimes.
Here are the essential pieces of information required for identity verification:
- Name
- Date of birth
- Address
- Identification number
These details can be verified by documents like passports, driver's licenses, or public utility bills. The customer onboarding process in high-risk industries may trigger enhanced customer due diligence checks on public databases, consumer reporting agencies, and watchlists.
Financial institutions must also maintain current and accurate customer information and continue to monitor accounts for suspicious and illegal activities. When detected, they are required to promptly report their findings.
Due Diligence and Verification
Due Diligence and Verification are crucial steps in the KYC process. Customer Due Diligence (CDD) is a critical element of managing risks and protecting against criminals, terrorists, and Politically Exposed Persons (PEPs).
There are three levels of due diligence: Simplified Due Diligence (SDD), Basic Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD). SDD is for low-risk situations, CDD is for verifying customer identity and assessing risks, and EDD is for higher-risk customers requiring additional information.
To perform CDD, you must ascertain the identity and location of the potential customer and gain a good understanding of their business activities. This involves locating documentation that verifies the name and address of your customer. You should also classify their risk category and define what type of customer they are, before storing this information and any additional documentation digitally.
Here are the three levels of due diligence:
- Simplified Due Diligence (SDD)
- Basic Customer Due Diligence (CDD)
- Enhanced Due Diligence (EDD)
Electronic KYC Verification (eKYC) is also an important aspect of the KYC process. It involves verifying a customer's identity using digital processes, such as APIs and biometric authentication. This can help speed up the onboarding process, reduce errors, and improve scalability.
What Are Documents?
When dealing with Customer Due Diligence, it's essential to collect the right documents to verify a customer's identity and assess their risk profile.
A government-issued ID is typically required as proof of identity, and some institutions may ask for two forms of ID, such as a driver's license, birth certificate, or passport.
To confirm a customer's address, proof of ID or an accompanying document is usually needed.
In some cases, a Simplified Due Diligence (SDD) may be sufficient for low-risk customers, but for others, a Basic Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD) may be necessary.
Here are some common documents required for CDD:
By collecting these documents, you can ensure that your Customer Due Diligence program is thorough and effective in verifying a customer's identity and assessing their risk profile.
Processes Are Key to Due Diligence and Compliance
Processes are key to due diligence and compliance. A well-structured process can help you stay on top of your regulatory obligations and protect your business from financial crimes.
To effectively manage your risks, you need to make sure a potential customer is trustworthy. Customer Due Diligence (CDD) is a critical element of this process, and it involves verifying the identity of a customer and assessing the risks associated with that customer.
There are three levels of due diligence: Simplified Due Diligence (SDD), Basic Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD). SDD is used in situations where the risk for money laundering or terrorist funding is low, while CDD is used for all customers to verify their identity and assess their risks. EDD is used for higher-risk customers to provide a deeper understanding of their activity and mitigate associated risks.
Some practical steps to include in your Customer Due Diligence program include:
- Ascertain the identity and location of the potential customer, and gain a good understanding of their business activities.
- Classify their risk category and define what type of customer they are, before storing this information and any additional documentation digitally.
- Carry out the correct processes to ascertain whether EDD is necessary.
- Keep records of all the CDD and EDD performed on each customer, or potential customer, in case of a regulatory audit.
Perpetual KYC helps keep awareness of untrusted risks through thorough ongoing CDD procedures, helping control and maintain compliance. Electronic Know Your Customer (eKYC) is a digital process used to verify customer identity and comply with AML regulations.
To determine whether EDD is required, consider factors such as:
- The customer's risk category
- Their business activities
- Their location
- Any other relevant information
By following these steps and using a well-structured process, you can ensure that your due diligence and compliance efforts are effective and efficient.
Ongoing Monitoring Framework
Ongoing monitoring is a crucial part of a KYC framework. It involves checking your customer on an ongoing basis to ensure their risk profile remains accurate.
This process includes oversight of financial transactions and accounts based on thresholds developed as part of a customer's risk profile. You need to monitor for spikes in activities, out of area or unusual cross-border activities, inclusion of people on sanction lists, and adverse media mentions.
Some other factors to consider when monitoring your customer include their account record being up-to-date, the type and amount of transactions matching the stated purpose of the account, and the risk-level being appropriate for the type and amount of transactions.
Periodical reviews of the account and the associated risk are also considered best practices. This helps ensure that your ongoing compliance obligations are met.
- Suspicious Activity Report (SAR) may need to be filed if the account activity is deemed unusual.
- Transaction monitoring relies on a risk-based assessment.
By implementing an ongoing monitoring framework, you can stay on top of your customer's risk profile and ensure your KYC program remains compliant.
Benefits and Importance
KYC monitoring is crucial in preventing money laundering and serious crimes associated with it. It's a vital part of anti-money laundering (AML) and counter-financing of terrorism (CFT) regulations.
Banks are required to perform KYC checks for every customer, making them compulsory. Only when minimum KYC requirements are met can a bank open a new account or continue a customer relationship.
KYC processes help prevent money laundering from going undetected, unlike periodic reviews which leave ample time for it to occur.
Industry-Specific
Banks are often the first to reflect new KYC requirements, as they provide a variety of financial services and deal with significant amounts of accounts, money, and transactions.
In the banking sector, KYC requires bankers and advisors to identify customers, beneficial owners of businesses, and the nature and purpose of customer relationships.
Banks must review customer accounts for suspicious and illegal activity and maintain the accuracy of customer accounts.
Technology is improving KYC and AML programs for banks with better identity verification speed, accuracy, and reliability. Leveraging APIs, AI/ML, biometrics, and advanced optical character recognition (OCR) technologies enables banks to gather more information and analyze it more intelligently.
Most other financial services have KYC requirements similar to banks, requiring them to perform KYC and monitor customer transactions to ensure they aren’t part of a money laundering scheme.
Financial service organizations need to verify the origin of larger sums and report cash transactions exceeding threshold limits.
To create a KYC crypto program, regulators and industry participants need to be aware of several red flags, including creating separate accounts under different names and initiating transactions from non-trusted IP addresses.
Here are some common red flags for KYC in the crypto industry:
- Creating separate accounts under different names
- Initiating transactions from non-trusted IP addresses
- Incomplete or insufficient KYC information
- Customers declining requests for KYC documents or inquiries regarding the source of funds
- Customers providing forged or falsified identity documents or photographs
- Customers who are on watch lists
- Customers who frequently change their identification information
Frequently Asked Questions
A Customer Identification Program (CIP) is a key component of KYC compliance, designed to verify the identity of customers.
KYC monitoring involves ongoing monitoring to ensure that customer information remains up-to-date and accurate.
Here are some key aspects of KYC monitoring:
Jumio's Help
Jumio's AI-powered solutions enable financial institutions to verify identities in real-time, making the process more efficient.
By using Jumio, banks and other financial institutions can replace manual KYC processes with automated ones, streamlining the online account setup and onboarding experience.
Jumio's identity verification and authentication solutions deliver key benefits to organizations striving to meet KYC and AML regulations.
Jumio's solutions have helped banks and other financial institutions maximize onboarding, making it easier for customers to access financial services.
Frequently Asked Questions
What are the three 3 components of KYC?
The three components of KYC are Customer Identification Program (CIP), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD), which work together to verify customers and assess their risk and financial profiles.
What are the 4 steps of KYC?
The 4 steps of Know Your Customer (KYC) are Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Ongoing Monitoring, which help businesses verify and assess the risk of their customers. By following these steps, businesses can ensure they are complying with anti-money laundering regulations and maintaining a secure customer base.
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