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Evidence Guide: FNSAML804 - Design customer due diligence policies and procedures

Student: __________________________________________________

Signature: _________________________________________________

Tips for gathering evidence to demonstrate your skills

The important thing to remember when gathering evidence is that the more evidence the better - that is, the more evidence you gather to demonstrate your skills, the more confident an assessor can be that you have learned the skills not just at one point in time, but are continuing to apply and develop those skills (as opposed to just learning for the test!). Furthermore, one piece of evidence that you collect will not usualy demonstrate all the required criteria for a unit of competency, whereas multiple overlapping pieces of evidence will usually do the trick!

From the Wiki University

 

FNSAML804 - Design customer due diligence policies and procedures

What evidence can you provide to prove your understanding of each of the following citeria?

Design processes for customer identification

  1. Design processes to collect information and documentation from different categories of clients
  2. Design processes for determining the ultimate beneficial owner of assets or funds where the client is a trust or fund or wealth management company
  3. Design a separate process for verifying client information and documentation
  4. Establish procedures for retention and retrieval of information and documentation from clients
  5. Design an assurance or oversight process to ensure all collection, verification, retention and retrieval processes comply with relevant AML/CTF rules
  6. Design processes for risk rating clients based on evaluating their characteristics, including jurisdiction and nature of business or occupation, with a financial crime specific risk framework
Design processes to collect information and documentation from different categories of clients

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design processes for determining the ultimate beneficial owner of assets or funds where the client is a trust or fund or wealth management company

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design a separate process for verifying client information and documentation

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Establish procedures for retention and retrieval of information and documentation from clients

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design an assurance or oversight process to ensure all collection, verification, retention and retrieval processes comply with relevant AML/CTF rules

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design processes for risk rating clients based on evaluating their characteristics, including jurisdiction and nature of business or occupation, with a financial crime specific risk framework

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design processes for identifying and monitoring customer behaviour

  1. Devise a process for determining a customer’s source of wealth
  2. Specify a control for identifying the source of funding for a transaction, where required
  3. Design a process for analysing the products utilised by a customer and considering how that may impact their risk profile
  4. Establish a procedure investigating the entities and individuals with whom a client is involved and whether this impacts their risk profile
  5. Determine the risk indicators that may apply to specific customers who represent an increased risk to the organisation
  6. Determine the specific monitoring, approval and review controls applicable to different client categories based on the risk that they represent for the organisation
Devise a process for determining a customer’s source of wealth

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Specify a control for identifying the source of funding for a transaction, where required

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design a process for analysing the products utilised by a customer and considering how that may impact their risk profile

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Establish a procedure investigating the entities and individuals with whom a client is involved and whether this impacts their risk profile

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Determine the risk indicators that may apply to specific customers who represent an increased risk to the organisation

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Determine the specific monitoring, approval and review controls applicable to different client categories based on the risk that they represent for the organisation

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design governance processes and controls for the customer due diligence processes

  1. Determine the assurance governance procedures for client identification and money laundering and terror financing (ML/TF) risk processes
  2. Determine the oversight framework for the customer due diligence procedure
  3. Design a governance framework for customer due diligence policies and procedures
  4. Design a process for ensuring that client risk assessment is consistent with the organisation’s risk appetite
  5. Specify processes for ensuring that customer due diligence policies and procedures are updated to reflect changes in regulation and organisational risk appetite
  6. Design and document the escalation procedure, including the escalation triggers and to whom issues will be escalated
  7. Design and document the exemptions policy and procedure
Determine the assurance governance procedures for client identification and money laundering and terror financing (ML/TF) risk processes

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Determine the oversight framework for the customer due diligence procedure

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design a governance framework for customer due diligence policies and procedures

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design a process for ensuring that client risk assessment is consistent with the organisation’s risk appetite

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Specify processes for ensuring that customer due diligence policies and procedures are updated to reflect changes in regulation and organisational risk appetite

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design and document the escalation procedure, including the escalation triggers and to whom issues will be escalated

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Design and document the exemptions policy and procedure

Completed
Date:

Teacher:		 Evidence:

 

 

 

 

 

 

 

Assessed

Teacher: ___________________________________ Date: _________

Signature: ________________________________________________

Comments:

 

 

 

 

 

 

 

 

Instructions to Assessors

Evidence Guide

ELEMENT

PERFORMANCE CRITERIA

Elements describe the essential outcomes.

Performance criteria describe the performance needed to demonstrate achievement of the element.

1. Design processes for customer identification

1.1 Design processes to collect information and documentation from different categories of clients

1.2 Design processes for determining the ultimate beneficial owner of assets or funds where the client is a trust or fund or wealth management company

1.3 Design a separate process for verifying client information and documentation

1.4 Establish procedures for retention and retrieval of information and documentation from clients

1.5 Design an assurance or oversight process to ensure all collection, verification, retention and retrieval processes comply with relevant AML/CTF rules

1.6 Design processes for risk rating clients based on evaluating their characteristics, including jurisdiction and nature of business or occupation, with a financial crime specific risk framework

2. Design processes for identifying and monitoring customer behaviour

2.1 Devise a process for determining a customer’s source of wealth

2.2 Specify a control for identifying the source of funding for a transaction, where required

2.3 Design a process for analysing the products utilised by a customer and considering how that may impact their risk profile

2.4 Establish a procedure investigating the entities and individuals with whom a client is involved and whether this impacts their risk profile

2.5 Determine the risk indicators that may apply to specific customers who represent an increased risk to the organisation

2.6 Determine the specific monitoring, approval and review controls applicable to different client categories based on the risk that they represent for the organisation

3. Design governance processes and controls for the customer due diligence processes

3.1 Determine the assurance governance procedures for client identification and money laundering and terror financing (ML/TF) risk processes

3.2 Determine the oversight framework for the customer due diligence procedure

3.3 Design a governance framework for customer due diligence policies and procedures

3.4 Design a process for ensuring that client risk assessment is consistent with the organisation’s risk appetite

3.5 Specify processes for ensuring that customer due diligence policies and procedures are updated to reflect changes in regulation and organisational risk appetite

3.6 Design and document the escalation procedure, including the escalation triggers and to whom issues will be escalated

3.7 Design and document the exemptions policy and procedure

Required Skills and Knowledge

ELEMENT

PERFORMANCE CRITERIA

Elements describe the essential outcomes.

Performance criteria describe the performance needed to demonstrate achievement of the element.

1. Design processes for customer identification

1.1 Design processes to collect information and documentation from different categories of clients

1.2 Design processes for determining the ultimate beneficial owner of assets or funds where the client is a trust or fund or wealth management company

1.3 Design a separate process for verifying client information and documentation

1.4 Establish procedures for retention and retrieval of information and documentation from clients

1.5 Design an assurance or oversight process to ensure all collection, verification, retention and retrieval processes comply with relevant AML/CTF rules

1.6 Design processes for risk rating clients based on evaluating their characteristics, including jurisdiction and nature of business or occupation, with a financial crime specific risk framework

2. Design processes for identifying and monitoring customer behaviour

2.1 Devise a process for determining a customer’s source of wealth

2.2 Specify a control for identifying the source of funding for a transaction, where required

2.3 Design a process for analysing the products utilised by a customer and considering how that may impact their risk profile

2.4 Establish a procedure investigating the entities and individuals with whom a client is involved and whether this impacts their risk profile

2.5 Determine the risk indicators that may apply to specific customers who represent an increased risk to the organisation

2.6 Determine the specific monitoring, approval and review controls applicable to different client categories based on the risk that they represent for the organisation

3. Design governance processes and controls for the customer due diligence processes

3.1 Determine the assurance governance procedures for client identification and money laundering and terror financing (ML/TF) risk processes

3.2 Determine the oversight framework for the customer due diligence procedure

3.3 Design a governance framework for customer due diligence policies and procedures

3.4 Design a process for ensuring that client risk assessment is consistent with the organisation’s risk appetite

3.5 Specify processes for ensuring that customer due diligence policies and procedures are updated to reflect changes in regulation and organisational risk appetite

3.6 Design and document the escalation procedure, including the escalation triggers and to whom issues will be escalated

3.7 Design and document the exemptions policy and procedure

Evidence of the ability to:

design organisational processes for customer due diligence including customer identification, identifying and monitoring customer behaviour and controls for the processes

document customer due diligence processes accurately and clearly using organisational formats and protocols.

Note: If a specific volume or frequency is not stated, then evidence must be provided at least once.

To complete the unit requirements safely and effectively, the individual must:

explain the money laundering and terrorism financing (ML/TF) customer due diligence process, including customer identification, identifying and monitoring customer behaviour and controls used

explain organisational processes and procedures for documenting and implementing policies and procedures

describe assurance governance procedures for customer identification processes

outline the key features and requirements of the legislative, regulatory and industry requirements for anti-money laundering and counter terrorism financing (AML/CTF).