Professional Documents
Culture Documents
(AML)
Customer Due Diligence (CDD)
Solution
Solution Guide
AML-CDD Version 2.0.8
Company Confidential
December 12, 2014
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Contents
Chapter 1: Overview ............................................................................................................... 1
1.1 About this Guide .......................................................................................................................... 1
1.2 About Customer Due Diligence ................................................................................................... 2
1.3 About the Actimize AML-CDD Solution ....................................................................................... 2
1.3.1 Main Features of the Actimize AML-CDD Solution ........................................................ 3
1.3.2 Key Objectives of the Actimize AML-CDD Solution ....................................................... 3
1.4 What’s New in This Version ......................................................................................................... 3
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Contents
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Contents
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Chapter 1: Overview
The Actimize AML-CDD Solution Guide is intended for use by the following personnel in financial
institutions:
• Compliance officers – responsible for compliance with anti-money laundering regulations.
• Operation center employees – responsible for reviewing and assessing solution alerts,
gathering missing information, and reviewing and managing customer responses.
• Relationship managers – typically the bank employees who are located at the bank's local
branches and have direct communication with the customers.
This document may describe features and capabilities that require a separate license and are not
covered by the standard license. For information about licensing please contact your Actimize
representative.
Examples included in this document are for the purpose of illustration and reference only.
Screenshots may look different from the screens in your solution, depending on your solution’s
configuration and the browser that is used.
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About Customer Due Diligence
Related Documents
The following documents are related to the Actimize AML Customer Due Diligence (CDD)
Solution Guide:
• Actimize AML Customer Due Diligence (CDD) Installation Guide
• Actimize AML Customer Due Diligence (CDD) Implementer’s Guide
• Actimize AML Foreign Account Tax Compliance Act (FATCA) Solution Guide
• Actimize AML Foreign Account Tax Compliance Act (FATCA) Web Services Guide
• Actimize AML Foreign Account Tax Compliance Act (FATCA) On-Boarding User’s Guide
• Actimize Risk Case Manager (RCM) Installation Guide
• Actimize Risk Case Manager (RCM) Reference Guide
• Actimize Visual Modeler & AIS Server Installation and Configuration Guide
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Overview
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What’s New in This Version
Search, Fetch, Get On-Boarding Party Data, and Update On-Boarding Party Data web
services. For more information, see Section 2.3 Actimize AML-CDD Web Services.
• Transient web service – Actimize customers can assess the risk level of a potential party by
calculating a hypothetical risk score, and without saving data in the database. For more
information, see Section 2.3 Actimize AML-CDD Web Services.
• Beneficial Ownership Records – The Beneficial Ownership tab in the customer record
details the ownership structure of the party. If the party is owned by other entities or
individuals, this tab shows the related information; such as the name, relationship type, and
the percentage of ownership. For more information, see Section 6.2.12 Reviewing Beneficial
Ownership Records.
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Chapter 2: Solution Summary
This chapter describes the solution methodology, solution flow, and web services for the Actimize
AML-CDD solution.
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Actimize AML-CDD Solution Methodology
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Solution Summary
A record is created for all customers, regardless of whether there are alerts associated with this
customer or not.
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Actimize AML-CDD Solution Methodology
The detection models usually run on a daily basis, updating the relevant customer profiles and,
when required, re-calculating their risk score. When model analytics identify CDD issues based
on the new profile, an alert is generated in the RCM Alerts tab.
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Solution Summary
data, find information on related events, and obtain detailed profiles for all accounts and
individuals involved.
Depending on the users’ roles and level of authority, they can reassign, escalate, or process
alerts from a personalized list, or a common (departmental) queue. Case Manager review
features enable users to modify the status and score of an alert, attach notes and other
documentation, and determine resolutions to alerts. The user can note and describe the
disposition of resolved alerts, and can optionally assign alerts to cases for a more focused review.
RCM provides the AML-CDD analyst with the tools to investigate customer records and any
customer-related alerts.
Authorized users can configure questions and answers that can then be used to on-board parties
to become new customers of the institution, and to create relationships between these customers.
Authorized users are also able to manually mark customers or accounts that should be removed
the next time a purge process is run by the solution. The purge actions are registered in an
appropriate audit trail log, including user comments explaining why a customer or account was
purged. By default, the solution regularly performs a cleanup process that purges old or obsolete
customers or accounts from the AML-CDD solution database (see Section 2.1.8 Solution
Cleanup, below).
In addition, the RCM Work Items module includes a list of all documents maintained within the
system. Each document is an instance of a supported document form such as OFAC License
Documents, FinCEN Registration Documents, etc. Authorized users can create new instances of
document forms or edit existing documents.
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Overview of the Solution Flow
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Solution Summary
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Chapter 3: Customer Risk Scoring
The Actimize AML-CDD solution comes with default out-of-the-box risk factors. Each organization
can select the relevant risk factors and define appropriate risk scoring scales according to its risk
assessment and policies.
Example:
Customer X has 4 accounts: 1111, 2222, 3333, and 4444
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Customer Risk Scoring
Customer Risk Score (X, Account Value) = MAX (0, 10, 0, 20) = 20
• If the Account Value risk factor is calculated by SUM aggregation, then:
Customer Risk Score (X, Account Value) = SUM (0, 10, 0, 20) = 30
• The total Customer Risk Score is the sum of all Customer Risk Factor scores.
• Customer Risk Score = SUM (Customer Risk Factors Score)
Example:
The following risk factor scores are assigned for Customer X.
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List of Solution Risk Factors
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Customer Risk Scoring
3.5.1 Countries
The Country List should include all relevant country ISO codes and a score allocated to each
country. The score value varies based on the client’s requirements.
Brunei BN 20
Kazakhstan KZ 20
Czech Republic CZ 15
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Risk Factor Score Reference Tables
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Customer Risk Scoring
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Risk Factor Score Reference Tables
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Chapter 4: CDD Detection Models
Each model identifies specific types of issues and generates alerts if the issues are detected.
The Actimize AML-CDD solution includes the following models:
• High Risk Customer
• Change in Customer Risk
• Identity Verification Issues
• Documentary Tracking
• Periodic Review
• Expected Behavior Deviation
In this example the following alerts would be generated for this customer:
• An alert is generated for the retail line of business (since the risk score is
greater than the specific business threshold).
• An alert is generated for the credit card industry for this customer (since
the risk score is greater than the specific business threshold).
Since there is no threshold specified for insurance, the solution uses the default
threshold for this line of business. In this case no alert is generated for insurance
since the customer risk score is less than the default threshold.
A total of two alerts would be assigned for this customer.
Each customer-risk score is based on risk factor scores assigned by this model (see Section 3.1:
About Risk Factors and Scoring Scales, page 12). In addition, AML-CDD analysts can fine-tune a
score manually by adding risk adjustments.
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Change in Customer Risk (CDD-INR)
When an alert is generated for this alert type, analysts can view the alert within the main Alert List
and can directly access, from the alert, the relevant customer’s Risk Factor Scores (see
Section 6.2.7: Reviewing Customer Risk Scores, page 60).
Detection Logic
1. For each new detected customer that is active:
a. Calculate Risk Score for all active Risk Factors.
b. Calculate Total Score by aggregating the Risk Scores.
2. For each detected customer that is not active:
a. Assign a Total Score of 0.
3. Generate an alert for each customer BU:
a. If a Minimum Score threshold exists for the customer BU and the Total Score ≥ BU
Minimum Score threshold.
b. If no threshold exists for the customer BU and the Total Score ≥ Minimum Score
threshold.
NOTE:
Risk Factors can be activated or de-activated by the implementer or authorized users using the RCM
Settings. Only active risk factors appear in the Customer Profile.
Thresholds
The business analyst is able to adjust the following threshold value using options available within
the Actimize Risk Case Manager:
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CDD Detection Models
• Number of risk levels – For example, if the risk level increased by 1 level or decreased by 2
levels, then the model generates an alert.
A risk level depends on the customer risk scores. The following table shows an example of
risk levels:
Detection Logic
1. Retrieve the latest customer total risk score that was calculated by the CDD-HRB model (see
above), or by the CDD-INR model.
2. Calculate a new customer total risk score.
3. Retrieve risk levels for the previous and current risk scores.
4. If running in No Threshold mode, generate an alert for each scanned customer.
OR
5. If running in regular mode, generate an alert if:
Risk level increased by at least No. of Risk Levels Increased threshold levels since last
scoring
OR
Risk level decreased by at least No. of Risk Levels Decreased threshold levels since
last scoring
OR
Risk score increased by at least Points of Risk Score Increased threshold points since
last scoring
OR
Risk score decreased by at least Points of Risk Score Decreased threshold points
since last scoring
OR
Risk score increased by at least Percentage of Risk Score Increased threshold
percentage since last scoring
OR
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Identity Verification Issues (CDD-CIP)
Thresholds
The business analyst is able to adjust the following threshold values using options available
within the Actimize Risk Case Manager:
Scoring
Scores are calculated based on active risk factors. For more information about Risk Factors see
Section 3.2: Risk Factor Score Calculation, page 12.
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CDD Detection Models
verification applications typically have access to confidential databases and can confirm whether
the details supplied match the government data (e.g. does the name associated with the ID
number match the name in the government records).
The Identity Verification Issues model tracks an institution’s documentary and non-documentary
customer information, and disseminates alerts upon detection of missing or incomplete
information, based on the Customer Identification Program requirements. This model assists the
financial institution to meet the mandates of the regulations, which require identification of key
information such as:
• Customer Name
• ID number
• ID type (when more than one type of ID is allowed)
• Date of birth
• Customer address
When an alert is generated for this alert type, analysts can view the alert within the main Work
Items Alert List and can directly access, from the alert, the relevant customer’s CIP records. For
more information about Customer’s CIP Records, see Section 6.2.6: Reviewing CIP Records,
page 60.
Detection Logic
1. Read all new discrepancy records from a discrepancy report (supplied by the client).
NOTE:
Each time CIP data is analyzed and a discrepancy is found, a new record is created.
2. Aggregate all new discrepancy records, per customer.
3. Generate an alert for each customer with new aggregated discrepancy records.
Scoring
The business analyst is able to adjust the following default score value using options available
within the Actimize Risk Case Manager:
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Documentary Tracking (CDD-DOC)
This model can also track the status of documents that are created within the RCM Work Items
module and can generate alerts if incomplete or insufficient documentation is detected (see
Section 6.3.3: Document Management, page 64).
Documents can be categorized into different document groups, thereby enabling the solution to
distribute separate alerts per document group. Each document group can be configured to
include one or more document type. For example: If one business group within the organization is
investigating SARs and another business group is investigating a different type of document, then
the model distributes alerts with the appropriate data to each of the appropriate business group of
users.
When a document type is associated with more than one document group, multiple alerts are
generated, one for each document group, including the relevant document type.
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CDD Detection Models
In the above example, a total of two alerts would be assigned for this
customer: one alert would be distributed to the ‘FIU’ Document Group, and a
separate alert would be distributed to the Default Document Group.
If different business groups are not defined for different document types, then
there would be only one alert for the customer for detected issues that refer to
all document types.
Detection Logic
1. For each customer document that was updated since the last time the model ran:
If Requirement Priority Code is on the Mandatory Documentary Requirements list,
then the Document is Mandatory.
If the Document Status Code is on Incomplete Document Status list, then the
Document is Incomplete.
If the Document Requirement Code is on Renewable Documents list, then the
Document is Renewable.
2. If the Document Requirement Code is within the Incomplete Document Reminder
Schedule list, then retrieve the appropriate Document Due Date from the client data and
perform the following:
a. Calculate Difference value = Document Due Date - Current Date.
b. If Difference Value ≤ ABS (From value in days), then the Document Is Relevant for
Incomplete Document Review.
c. Retrieve the Frequency Period associated with the From value within the Incomplete
Document Reminder Schedule list. If Difference Value ≤ ABS (From value) for more
than one From value, take the MIN(ABS (From value in days) for retrieving the
frequency.
3. If the Document Requirement Code is within the Document Renewal Reminder Schedule
list, then retrieve the appropriate Document Expiration/Renewal Date from the client data
and perform the following:
a. Calculate Expiration Difference value = Document Expiration/Renewal Date - Current
Date.
b. If Expiration Difference value ≤ ABS (From value in days) then Document Is Relevant
For Renewable Document Review.
c. Retrieve the Frequency Period associated with the From value within the Document
Renewal Reminder Schedule list.
If Expiration Difference value ≤ ABS (From value) for more than one From value, take
the MIN(ABS (From value in days)) for retrieving the frequency
4. Generate alert if:
Document is Mandatory and Document is Incomplete and Document Is Relevant for
Incomplete Document Review and no alert was created in the current Frequency Period,
based on the Incomplete Document Reminder Schedule.
OR
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Documentary Tracking (CDD-DOC)
Lists
The business analyst must populate the relevant lists using options available within the Actimize
Risk Case Manager:
Scoring
The business analyst is able to adjust the following default score value using options available
within the Actimize Risk Case Manager:
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CDD Detection Models
Risk Level Risk Level Name From Score Periodic Review (Days)
1 Low risk 0-99 -
2 Medium risk 100-199 365
3 High risk 200-299 180
4 Very high risk ≥300 90
When calculating the next review date, the model also takes into account reviews that were
conducted outside of the normal review schedule, for example due to some other CDD issues
identified by the system.
When the customer is due for a review, the CDD-PRE model automatically generates an alert into
a special work queue to notify the relevant team that a review should be conducted, thereby
ensuring that periodic review policies and procedures are applied without fail.
Detection Logic
1. Determine the Review Period based on the customer risk level (see Section 2.1.5: Detection
and Alert Generation, page 7).
2. For each customer related alert retrieve Related Cases.
3. Calculate Customer Last Review Date = the latest of:
a. Last review date from Party Table.
b. Last date the customer was reviewed based on the customer status. A customer is
considered reviewed if the customer status is on the Customer Reviewed Status list.
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Expected Behavior Deviation (CDD-EBD)
c. Last date the customer alerts were reviewed based on Alert Type and Alert Status. An
alert is considered reviewed if the alert status is on the Customer Reviewed Alert
Status list and the Alert Type is on the Customer Reviewed Alert Type list.
d. Last date the Related Cases were reviewed based on Case Type and Case Status. A
case is considered reviewed if the case status is on the Customer Reviewed Case
Status list and the Case Type is in the Customer Reviewed Case Type list.
4. Generate alert if: Customer Last Review Date + Review Period is before or on the current
date then customer is relevant for review.
Lists
The business analyst must populate the relevant lists using options available within the Actimize
Risk Case Manager:
Scoring
The business analyst is able to adjust the following default score value using options available
within the Actimize Risk Case Manager:
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CDD Detection Models
activity exceeds the anticipated (i.e., previously declared) monthly activity by a pre-defined
percentage, then an alert is triggered.
The financial institution can configure which related account activity should contribute to the
monthly sum of activities. The model can retrieve profile data for an account or customer from a
variety of sources, including Actimize AML-SAM or other data sources.
Detection Logic
1. Calculate Sum of Customer Activity for the previous month based on Transaction Type
Codes for Monthly Activity list.
If customer activity is calculated based on related accounts, then identify customer related
accounts based on the Relation Types list and calculate activity as sum of related account
activity.
2. If Sum of Customer Activity ≥ Minimal Monthly Activity threshold
Then
a. For each service type, retrieve Account Expected Monthly Value
b. For each service type, retrieve Account Expected Monthly Volume
c. For each service type, retrieve or calculate Customer Expected Monthly Value
d. For each service type retrieve or calculate Customer Expected Monthly Volume
e. For each service type, calculate the Account Profile Monthly Value
f. For each service type, calculate the Account Profile Monthly Volume
g. For each service type, calculate the Customer Profile Monthly Value
h. For each service type, calculate the Customer Profile Monthly Volume
3. Generate alert if, for one or more service types:
o Account Profile Monthly Value exceeds Account Expected Monthly Value by at
least Percentage Exceeds Expected Account Monthly Value threshold.
OR
o Account Profile Monthly Volume exceeds Account Expected Monthly Volume by
at least Percentage Exceeds Expected Account Monthly Volume threshold.
OR
o Customer Profile Monthly Value exceeds Customer Expected Monthly Value by
at least Percentage Exceeds Expected Customer Monthly Value threshold.
OR
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Expected Behavior Deviation (CDD-EBD)
Scoring
The business analyst is able to adjust the following default score value using options available
within the Actimize Risk Case Manager:
Lists
The business analyst must populate the relevant lists using options available within the Actimize
Risk Case Manager:
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CDD Detection Models
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Chapter 5: On-Boarding Parties
The Actimize AML-CDD solution enables representatives of the financial institution to on-board
new parties, or entities, via a coordinated series of pre-defined questions that are presented in
the On-Boarding tab. For each new customer, an on-boarding client alert is generated, and a
customer record is created. Users can view and process on-boarding client alerts like other alert
types (as explained in Chapter 6: Review and Investigation, page 56).
5.1 Overview
The on-boarding procedure is fully configurable. First, business analysts need to define a
question flow for different party types that will be on-boarded via the normal on-boarding forms or
web services. This analytical process of defining a question flow consists of:
• Creating questions
• Defining possible answers
• Organizing questions into sets
• Determining the flow of questions (when to ask certain sets of questions).
After defining the question flow, authorized implementers can configure the on-boarding process
by performing the following:
• Creating party types – Different types of parties can be defined for on-boarding, and each
party is presented with its own set of questions during the on-boarding process.
• Organizing question sets into tabs – A series of predefined questions is presented to the
prospective Financial Institution officer user (typically the on-boarding Relationship Manager).
Questions and answers are recorded by the Actimize AML-CDD solution for risk scoring.
High-risk customers may need to answer enhanced due diligence (EDD) questions that are
displayed in the EDD tab.
• Defining Next Set expressions – Supplementary questions may be presented to the
customer based upon answers already provided. Dynamic on-boarding forms are created
automatically based on available data in the Q&A engine. When data in the Q&A engine is
updated, the forms are automatically updated.
Authorized users can configure the on-boarding process via the following options:
• On-Boarding Config tab
• Settings > References > On-Boarding action menu
• Questions & Answers option of the Settings > References > CDD action menu
See the Actimize AML-CDD Implementer’s Guide for more information about configuration.
In order to perform on-boarding of new parties, the user (typically the on-boarding Relationship
Manager) must be assigned special permission.
The workflow may have been configured according to your business policy to approve or reject
submitted parties. By default, such workflow steps are not configured, but may have been
provided by Actimize Professional Services as a special customization.
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On-Boarding Parties
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On-Boarding a New Party
Based on the above diagram, if a user belongs to the business unit called BU_B, which appears
as a sub-business unit for BU_A, then the user is exposed to the data of parties that are
associated with the following business units: BU_B, BU_D, and BU_E.
NOTE:
If a business unit belongs to more than one hierarchy, then users who are assigned to this
business unit might be exposed to customer data pertaining to all hierarchies, based on the
above logic.
2. When the forced on-boarding search mechanism is turned off (default setting), you can
either search for an existing party, or start on-boarding a new party (links displayed in red in
screenshot above).
3. When the forced on-boarding search mechanism is turned on (configurable), you must first
check whether a customer already exists (the new on-boarding links are not displayed in the
screenshot above). The AML-CDD solution does not allow you to on-board a new party
without first searching if the customer already exists, in order to prevent on-boarding
of existing parties. Use the Basic Search fields at the top of the tab to check if a party
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On-Boarding Parties
already exists in the Actimize AML-CDD database. This applies to both Advanced and
Related searches.
NOTE:
The new on-boarding links are only displayed after performing a search, and verifying that the
customer does not exist in the Actimize AML-CDD database.
If the customer already exists in the Actimize AML-CDD database, you can view, and
optionally modify, an existing on-boarding questionnaire for a party who is either in the
On-boarding or Approved state.
If the customer does not exist in the Actimize AML-CDD database, the message “No
results were found with the search criteria” appears and the new on-boarding links are
displayed. You can then proceed to on-board the new party.
For information on how to configure the forced on-boarding search mechanism, refer to the
Actimize AML-CDD Implementer’s Guide.
4. Click the relevant party type link to begin on-boarding a new party. Party types depend on
how your deployment has been configured, but might typically include Individual and
Organization.
The relevant party type questionnaire opens. Questions are organized in several tabs,
according to the configuration that has been created for the chosen party type.
NOTE:
Different party types may be used to distinguish between parties for different lines of
business (e.g. mortgage – account opening, loans – guarantees, etc.).
If you leave all search fields blank when you perform the search, all the on-boarding records
will be displayed.
5. Enter the details into the On-Boarding Questionnaire page. As you enter the party’s
responses to these questions in the Questionnaire page, a read-only summary of details that
have been entered is added to the Summary tab on the right of the page.
6. Click Save at any stage of the on-boarding process to save your input.
A new on-boarding party record is added, and the Party Information Highlight bar appears at
the top of the window. The on-boarding party is not added to the Customers list until it is
accepted.
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On-Boarding a New Party
NOTE:
At any stage during the on-boarding process you can quit by clicking the Cancel button. A
message appears warning you that you will lose any information you have not yet saved.
In general, when completing an on-boarding record:
Mandatory fields marked with an asterisk (*) – You will not be able to submit the new
record unless these fields contain verifiable data.
Online help fields followed by a question mark ( ) – By hovering your cursor over this
mark you invoke a tooltip containing any description of the field that was included when it
was configured (if applicable). By clicking the mark you will invoke a new window
containing the page of online help that was associated with the field when it was
configured (if applicable).
7. Select each tab in the On-Boarding Questionnaire page to bring it forward and continue
entering party details.
Typical tabs in the On-Boarding Questionnaire page might appear as follows:
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On-Boarding Parties
Question Types
A question that is configured to be dynamic depends on the answer already supplied to another
question. For example, selecting “USA” as the country of residence may populate a drop-down
list of appropriate states:
In another example, when you select a certain answer to one question, a set of applicable follow-
up questions may be displayed, which were not applicable (and hidden) if you had chosen a
different answer.
In the example below, if “None Available” is selected for the Identification Number Type, then the
“Please Explain” field appears prompting the user to provide an explanation.
A multiple-type question permits users to select more than one answer from a list:
8. Click Save at any stage to add a new customer record on the database.
When you save the record for the first time, the Party Information Highlight section is
added at the top of the page as shown in the following example.
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On-Boarding a New Party
The fields displayed here are configurable for your deployment, and you can collapse the
section if you want.
At this stage, the customer record’s status is On-Boarding.
At any stage, saving the record applies a data integrity check on answers entered so far and
any syntax errors will be reported. Each subsequent save, validate, or submit operation will
update the customer record.
An alert of the On-boarding Client type is generated, which can be viewed in the RCM
Workbench > Work Items list. At this stage, the alert’s status is Still in On-Boarding process,
and no customer details are presented.
9. When you are satisfied with the answers entered in all tabs of the On-Boarding Questionnaire
page, navigate to the Summary tab to review the questions and answers supplied.
The Summary tab includes basic details of the party record, the user who created it and
expandable sections for each of the tabs of the On-Boarding Questionnaire page.
10. Click Validate. The solution verifies the input details.
If any fields do not contain input, these are highlighted on the Summary tab.
If any mandatory fields do not contain verifiable input, a warning message is displayed.
11. Return to previous tabs of the On-Boarding Questionnaire page to complete missing details
as necessary.
12. When all required details have been entered, click Save and then return to the Summary tab.
Click Validate. If all mandatory fields are validated, the solution performs a basic risk
scoring check and presents the results in the Summary tab. If the calculated risk level
exceeds the configured threshold, an additional set of Enhanced Due Diligence (EDD)
questions is added to the On-Boarding Questionnaire page. For information on how to
complete the EDD tab, see Section 5.4.2 Enhanced Due Diligence (EDD) Tab.
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On-Boarding Parties
If the calculated risk level is below the configured threshold, a message is displayed
confirming the successful validation. Click Submit in the Summary tab to complete the
process. A message is displayed confirming the successful submission.
Depending on configuration, party data can be sent to external bank systems upon submit.
While the record is in On-boarding under review status, the party’s profile is frozen, and an on-
boarding client alert is generated.
The on-boarding entry is locked for editing until the party is accepted as a client. Any user with
access to the On-Boarding tab can search for the party, and open the party’s On-Boarding
Questionnaire page in read-only form. In this form all the entry fields are grayed out, and no Save
or Submit buttons appear at the bottom of the page.
When in On-boarding under review status, the party record can be modified only by the RCM
owner. The party record can be exported to PDF.
NOTE:
A user who is not assigned the OB_EditAllowed role will always see a read-only version of an
on-boarding record.
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On-Boarding a New Party
2. When the EDD questions have been answered, return to the Summary tab and click Save
and Validate until no errors are detected.
The AML-CDD solution repeats the basic risk scoring check and presents the results in the
Summary tab.
3. Only when no validation errors are detected, click Submit in the Summary tab to complete
the process. A message is displayed confirming the successful submission.
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On-Boarding Parties
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Viewing the On-Boarding Client Alert
See Chapter 6: Review and Investigation, page 56 for more information about alerts.
An alert is created for a new on-boarding record the first time the user clicks the Save button.
Until the new party record has been submitted the alert’s Party Name column will be blank and
you will not be able to view any details within it.
If you click the link in the Item ID column a message is displayed as follows:
When the party record is submitted, the Party Name column will be completed and you can view
details by clicking the link in the Item ID column. The alert captures a read-only snapshot of the
party’s profile.
The Customer Highlights section at the top of the alert displays the party’s name, customer key,
score, risk level and alert status. The details that were displayed in the Summary tab of the On-
Boarding Questionnaire page are also displayed on the On-boarding Questionnaire tab of the
alert.
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On-Boarding Parties
Other details may be displayed in the Customer Profile tab, depending on how the questions are
configured. The Risk Scoring tab, which is displayed by default, may enable an authorized user to
decide whether or not to accept the on-boarding party as a customer of the institution.
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Relating a New Party to the Current Party
A list of all the actions performed on the alert is displayed, including answers to on-boarding
questions, and any updates to those answers that may have been entered.
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On-Boarding Parties
2. Click the Search Existing link to open the Related Party Search window. If the forced on-
boarding search mechanism for related parties is turned on, you must first search for an
existing party in the AML-CDD database. This mechanism prevents the user from creating a
new related party that already exists in the database.
A new window opens containing the following fields enabling you to search for the relevant
party. The available search fields depend on your configuration.
The above search options are the defaults, but your deployment may have been customized
to use other search fields, or to allow selection from drop-down lists. When the search is of
the exact or partial match type, it is also configurable per field.
4. Enter the relevant details and click Search.
The results of any party records matching the search are displayed, as shown in the example
below.
If more than 1000 party records match the search criteria, a message is displayed asking you
to enter further search values so as to narrow the search. If your user permissions deny you
access to any of the parties that would have been returned by the search, a message is
displayed to notify you accordingly.
5. Click the link in the CSN column of the search results to select the party as the basis for the
new on-boarding related party.
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Relating a New Party to the Current Party
The new party is entered in the Related Parties tab of the current party. The details of the
related party are not editable within the Related Parties tab.
6. Proceed to Section 5.6.3 Adding a Related Party to the Current Party to add the selected
related party to the current party being on-boarded.
• If the configurable forced on-boarding search mechanism is turned on, users must first
search for an existing related party in the database when adding a related party. If the related
party does not exist in the database, only then are the new related party links displayed (as
shown in the screenshot below):
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On-Boarding Parties
A version of the On-Boarding Questionnaire page is displayed in the window with appropriate
entry fields and options enabling you to identify the party.
3. Select each tab in the On-Boarding Questionnaire page to bring it forward and continue
entering the party’s details as usual.
4. Save the new on-boarding record.
A message appears in the Related Parties tab of the “parent” party indicating that the party
relationship has been recorded and the highlights of the related party will be shown when you
click Save. The details of the related party are not editable within the Related Parties tab.
NOTE:
The related party record is added to the party profile as a new party.
5. Proceed to step 2 in Section 5.6.3 Adding a Related Party to the Current Party to add the
selected related party to the current party being on-boarded.
2. From the Relationship Type drop-down list, select an option to indicate how this party is
related to the current party, such as “Is the Spouse of” or “Company Director.”
This field is mandatory and if you forget it your related party may become an orphan (see
Section 5.6.4 Orphan Related Parties).
3. Click Save to save the update to the current party record.
Additional links appear as follows:
• Remove – Enables you to remove the party-party relationship. A message appears
reminding you to save the record to confirm this action. Note that this does not delete the
related party’s source record, which remains active on the system.
• Show Details – Enables you to open a Related Party Details window to confirm you chose
the correct related party.
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Relating a New Party to the Current Party
• Add – Enables you to add a new box containing a set of links to define another related party
by either of the methods described above (create new or search existing). The following
screenshot shows two related party boxes:
4. When you finish adding party-party relationships, you can click Save and validate the record.
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On-Boarding Parties
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Cloning an On-Boarding Record
3. Select the relevant checkboxes to clone the information from the Related Parties and
Enhanced Due Diligence (EDD) tabs.
If the original party only has related parties, or only EDD information, then only the relevant
checkbox is displayed. If the original user has neither, then this screen is skipped entirely,
and the cloned party is displayed.
NOTE:
If the user selects to clone EDD information from a specific party, then the cloned party is set
to EDD Required, and the EDD tab is visible. The EDD tab behaves in the same way as if it
would be required due to high risk scoring, although no scoring has yet been done. Whether
the individual answers are also cloned depends on the setting of the clonable flag for those
questions.
4. Click Submit to display the new cloned party with the related party and EDD information.
5. The fields are already populated from the original party record. You can edit the fields as
required to create a version of the selected record.
6. Select each tab in the On-Boarding Questionnaire page to bring it forward and continue
entering the party’s details as usual.
7. For any questions where answers have defaulted from the source, you can choose
replacement values as required.
8. Save, validate and submit the new on-boarding record to complete the process. The same
messages are displayed to the screen as when creating any other on-boarding record and
you may be expected to fix syntax errors or answer enhanced due diligence (EDD) questions.
If an On-boarding Client alert already exists for the party, then it is updated.
If no On-boarding Client alert exists for the party, then an alert is generated.
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On-Boarding Parties
2. In the Basic Search fields at the top of the page, enter sufficient details to identify the existing
party you are interested in.
The Basic Search options may have been customized for your deployment to use different
search fields, or to allow selection from drop-down lists. Each field can also be configured to
determine whether the search is of the exact or partial match type.
3. Click Search to perform the search, and then continue from step 6 below.
If more than 1000 party records match the search criteria, a message is displayed asking you
to enter further search values so as to narrow the search. If your user permissions deny you
access to any of the parties that would have been returned by the search, a message is
displayed to notify you accordingly.
4. If you don’t see the search category you need in the entry fields at the top of the page, click
the Advanced Search button to display the Advanced Search window:
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Cloning an On-Boarding Record
Field Description
Account Number The number of an account owned by the party.
CSN The identification number of the party.
First Name The party’s forename.
Last Name The party’s surname.
Doc number The number of the party’s primary identification document, e.g.
passport number.
RM Manager The party’s relationship manager, as identified during the on-
boarding process. When a record is successfully validated, the user
who performed that action is identified as the relationship manager.
Creator The username of the user who was logged on when the party
record was created.
Address Line 1 The first line of the address provided when the party was recorded.
Address Line 2 The second line of the address provided when the party was
recorded.
City The city part of the address provided when the party was recorded.
State/Province The state/province part of the address provided when the party was
recorded.
PO Box The PO Box part of the address provided when the party was
recorded, if applicable.
Zip Code The zip or postal code part of the address provided when the party
was recorded.
Party Status The status of the party record, such as On-boarding, or On-boarding
waiting for review.
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On-Boarding Parties
The above Advanced Search options are the defaults, but your deployment may have been
customized to use other search fields, or to allow selection from drop-down lists. When the
search is of the exact or partial match type is also configurable per field. Click Search at the
bottom of the Advanced Search window to perform the search.
The results of any party records matching the search are displayed.
If more than 1000 party records match the search criteria, a message is displayed asking you
to enter further search values so as to narrow the search. If your user permissions deny you
access to any of the parties that would have been returned by the search, a message is
displayed to notify you accordingly.
6. Select the option button at the left end of the required row of party search results to identify
the source record.
7. Optionally you can click the View Details link in the Details column of the search results to
open the Party Details window to help your selection:
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Changing the Party Type of an On-Boarding Record
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On-Boarding Parties
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Chapter 6: Review and Investigation
6.1 Overview
The Actimize Risk Case Manager includes options and features that enable authorized users to
investigate customer records, all alerts generated as a result of CDD issues and any documents
associated with customers.
The user can review and investigate any selected customer record from the ‘Customer Module’ of
the RCM. In addition, the RCM user can easily access and investigate all alerts related to the
customer.
From the Customer Module the AML-CDD analyst can perform the following tasks:
• Search for a required customer
• Review a customer record, including customer profile, account profile, customer account
relations, related documents etc.
• Jump to alerts related to the customer
• Manage all customer documents
• Add notes to a record
• Adjust risk factor scores
• Audit the history of any updates made, or comments/documents added, to a customer record
From the ‘Work Items’ module the AML-CDD analyst can perform the following tasks:
• Review all alerts detected by the solution, based on the ‘alert type’
• Review all customer documents
• Create a new customer document based on available document forms
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Review and Investigation
Users can then click on the Customer Name link within the resulting list of customers and view
the related CDD information pertaining to that customer.
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Workflow for Reviewing a Customer Record
1. Header Information and Action Buttons – This pane includes information that is relevant
for the current record and basic actions that can be performed on the customer record such
as jump to the customer's alerts, manage customer documents, view all customer profiles or
add notes.
2. Customer Highlights – This pane provides highlights of the customer details, including the
current risk score record information and main customer attributes.
3. Customer Record Tabs – The tabs within a CDD customer record are:
Customer Profile – With customer level information
Account Profile – With account level information
CIP Record – With ‘Customer Identification Program’ information
Risk Scoring – With all risk factor scores assigned for the customer
Onboarding Questions – With a summary of questions presented to the party and
answers given by the party during the on-boarding process
Relation Diagram – Displaying a link analysis with all related customer accounts
Audit – Providing a full audit trail on user actions
Related Docs – With documents related to the customer, which may be uploaded by the
user or via a web service
Beneficial Ownership – Details the ownership structure of the party. If the party is
owned by other entities or individuals, this tab shows the related information; such as the
name, relationship type, and the percentage of ownership.
Field/Option Description
Displays the customer record ID.
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Review and Investigation
Field/Option Description
Opens the ‘Workbench – Work Items’ module
and displays all alerts related to this customer.
Opens the ‘Add Note’ window that enables the
user to add a note to a selected customer
record. This action is recorded within the ‘Audit
History’ of the customer record.
Authorized Users can change the status of the
customer. This action updates the customer’s
status within the customer’s profile.
Authorized users can use this button to open
the ‘Workbench – Work Items’ module and
display all documents related to this customer.
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Workflow for Reviewing a Customer Record
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Review and Investigation
enables analysts to make adjustments to the risk level or risk scores, and to view the history of
previous risk scoring.
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Workflow for Reviewing a Customer Record
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Review and Investigation
documents (up to 50MB in size) and deleted existing documents. All such changes are saved and
can be reviewed on the Audit tab.
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Options for Reviewing AML-CDD Items and Item Details
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Review and Investigation
Once the document is saved it appears under the Summary tab of the relevant customer record.
Users can manage all customer documents from the customer record by selecting the Manage
Documents button at the top of the window.
After reviewing or editing the required documents within the Work Items page the user can return
to the customer record using a ‘Back to Customer’ option. The documents remain active until they
expire and then appear within the Summary sub tab as expired.
Documents that are created within the RCM can be checked by the CDD Documentary Tracking
(CDD-DOC) detection model which tracks the status of customer documentation. The model, for
example, can check the documentation expiration date and can distribute an alert if an issue is
detected.
For more information about the Documentary Tracking model see Section 4.4: Documentary
Tracking (CDD-DOC), page 24.
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Adjusting Thresholds and Scoring Scales
Thresholds are upper and lower limits that are used by the solution logic when assigning scores.
In some cases the thresholds are predefined and cannot be adjusted. However, in many cases
the user has the ability to adjust these upper and lower limits in order to fine-tune the number of
alerts that are generated.
The scoring scales define different segmentation levels for each risk factor and the score values
that are associated with each segment. These values are used, each time the corresponding risk
factor is activated, in order to assign the appropriate score.
6.4.1 Thresholds
Clicking the Threshold link enables the user to view default values for all thresholds that are
available for adjustment. When required, users can enter user-defined values in order to fine-tune
the process to suit their immediate tasks and needs.
For example, the user could select the ‘Days to expiration’ threshold within the list and use the
available Edit button at the top of the page to modify the value for this threshold, as shown in the
example below:
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Review and Investigation
Clicking the Scoring link enables the user to view default values for all scoring scales that are
used to determine the assignment of score values. When required, the user can enter user-
defined values in order to fine-tune the process to suit their immediate tasks and needs.
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Viewing and Managing Solution Lists
Each risk factor has a scoring scale that defines the different segmentation levels for that score
factor and score values that are associated with each segment. These values are used each time
the corresponding risk factor is activated.
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Review and Investigation
The example shown below is the list of risk factors that is referenced when the solution evaluates
the risk level of a customer. This list includes all risk factors and an indication of whether the
factor is currently active.
When a user score value is entered for a list member, this value is used instead of the default
value. The user can return to the default values at any time by removing the user-defined values.
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Chapter 7: CDD Maintenance Model
The solution includes a ‘Purge of Old Records’ model that is designed to purge old or obsolete
records from the solution’s database. This model provides the facilities by which organizations
can define a policy for cleaning customer and account records that are considered inactive. The
model monitors for customer or account records that have been inactive for a period of time and
implements either a full or partial purging process based on the financial institution’s
requirements.
The financial institution can ensure that the CDD database is synchronized with the banking
systems, maintain updated information about customers and accounts within the AML-CDD
solution, and remove outdated records.
During the implementation stage, a purge policy for ‘inactive’ customers and accounts is defined
based on the financial institutions requirements. The solution runs separate logic to determine
which customers to delete and which accounts to delete. The reason for this is:
• An account may be connected to multiple customers and some of these customers could still
be active
• A current (active) customer can have old accounts that should be deleted
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CDD Maintenance Model
• The ‘old’ account is deleted from the current profile of any related customers. Historical
snapshots of those related customers and other related items, such as related customers or
workflow items, are not deleted.
• Once an account is purged, the related customers’ profiles are updated, i.e., new profile
records are created, while previous ones are stored in the respective history.
Authorized users also have the ability to manually flag an account to be purged the next time the
purge process runs. The authorized user can add comments that will not be deleted and will stay
as part of the audit trail.
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Old Account Purge
2. Retrieve manually entered inactive accounts from the Manual Account Purge list.
3. Purge accounts if account is old or was manually marked to be purged.
Flexibility:
Thresholds and Settings:
The business analyst is able to adjust the following threshold values using options available
within the Actimize Risk Case Manager:
Lists:
The business analyst must populate the relevant lists using options available within the Actimize
Risk Case Manager:
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CDD Maintenance Model
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Chapter 8: AML-CDD Policy Manager
The license for the AML-CDD Policy Manager module is purchased separately.
8.1 Overview
Authorized users can set up and activate a policy of rules for the Policy Type that is delivered with
the AML-CDD solution. Rules created in the Policy Manager are used to define risk factors.
Active rules are evaluated when the customer risk score is checked as part of the risk scoring
process. If conditions defined within the rules are met, the relevant risk factor is used to adjust the
score assigned to any affected party. If the total score of the rules exceed the minimum alert
score then an alert will be generated for this party.
The policy can be made up of one or more rules that determine the response to the rule’s
conditions.
Risk score and level are determined by a combination of a default out-of-the-box value, a custom
value, if set, and an adjustment if rule criteria are met.
When a rule includes an action to adjust the risk level, AML-CDD will choose the highest risk level
from the default, custom and rule-determined levels.
For example:
The following risk levels are applicable:
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Policy Manager Rules
Then the following risk score will apply for Party A, Party B and Party C:
Party A: A red engineer
The party’s occupation does not cause the default risk score to apply (+0); the party’s color does
not cause the custom risk score to apply (+0); but the first policy rule does apply (+100).
Risk Score = 100, therefore Risk Level = Medium
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Policy Manager Rules
• Clicking the Rule Name link displays the criteria for the rule:
• This example includes only one condition, but more complex rules can be defined if required.
• Once conditions are defined, select a value for the ‘Adjust Risk Level’ action and/or the
‘Adjust Score’ action.
Adjust Risk Level – Select the risk level value to which the party should be set when the
criteria for the rule are true.
Adjust Score – Select a negative value to reduce the risk score if the rule criteria are true,
or select a positive value to increase the risk score. Available score values are as follows:
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Examples of User-Defined Policies
• Users can define multiple rules for a Policy Type, and then activate only a sub-group of all the
rules. The solution executes only the active rules.
In the example presented above, the following actions were defined for the rules:
• Example Rule 1 – When the party’s Active Date is within three months prior to today’s date,
then increase the risk score by 50.
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Examples of User-Defined Policies
• Example Rule 2 – When the party’s Occupation is “BANKER”, then set the risk level to
“Low”.
• Example Rule 3 – When the party’s Occupation is “SINGER”, then set the risk level to
“High”.
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Chapter 9: Risk Factor Specifications
The Actimize AML-CDD solution analyzes a wide variety of data elements and risk factors to
assign a score to each customer. The risk score calculation is based on the client’s risk factors
and reference risk scoring tables, as well as a history of the risk score.
This section provides a list of risk factors used in the Actimize AML-CDD solution, as well as their
specifications.
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List of Risk Factors
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
THEN
MAX (
Score (
All Party ‘Address Zip Codes’
AND
All related Account ‘Address Zip Codes’
)
Based on ZIP SCALE scoring scale
)
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
DEFAULT SCORE
CITIZENSHIP COUNTRY RISK score =
IF
Party Citizenship Country <> LOCAL COUNTRY
THEN
Score based on COUNTRY SCALE scoring scale
ISSUE COUNTRY RISK score =
MAX (
Score (
All Issued Countries of Party Documents
Excluding LOCAL COUNTRY
)
Based on COUNTRY SCALE scoring scale
)
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
9.2.18 Occupation
Model CDD-RSK [ Customer Risk Scoring ]
Risk Factor Calculates the level of risk associated with the customer’s
Description occupation code.
Risk Factor ID CDD-RSK-018-PTY-OCP
Risk Factor Name Occupation
(display)
Scoring Algorithm IF
Occupation Code <> NULL
THEN
Score = OCCUPATION score
ELSE
Score = DEFAULT SCORE
Scoring OCCUPATION score =
Calculations Score based on OCCUPATION SCALE
Default Values DEFAULT SCORE = 10
Scoring Scales OCCUPATION SCALE [ based on the reference table for
occupation code scales]
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
Score = 0
Scoring Calculations HIGHEST PARTY BASE RISK score =
MAX (
All relationship scores of related parties multiplied by the premium
weight of their defined risk levels.
)
RELATIONSHIP PREMIUM score =
IF
Party Account Party Relationship
THEN
MONITORED PARTY to ACCOUNT RELATION score
*
ACCOUNT to HIGHEST PARTY RELATION score
*
RISK LEVEL PREMIUM score
/
100
ELSE IF
Party Party Relationship
THEN
PARTY to PARTY RELATION score
*
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CDD-RSK Risk Factor Specifications
Parties related
to the Accounts
HRB Score = 30
Related Accounts P2
HRB Score = 60
A1
Monitored Party P3
HRB Score = 150
A3
P5
Y- Relation score
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
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CDD-RSK Risk Factor Specifications
Scoring Algorithm IF
Party Behavioral Trends <> NULL
THEN
Score(
related Behavioral Trends Code
)
Based on BEHAVIORAL TRENDS SCALE scoring scale
ELSE
Score = 0
Scoring Scales BEHAVIORAL TRENDS SCALE [based on behavior trends
reference table]
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CDD-RSK Risk Factor Specifications
Scoring Scales CLIENT NET WORTH SCALE [based on rule scoring scale]
COMPANY CONFIDENTIAL
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About NICE Actimize
NICE Actimize is the largest and broadest provider of financial crime, risk and compliance solutions for
regional and global financial institutions, as well as government regulators. Consistently ranked as number
one in the space, NICE Actimize experts apply innovative technology to protect institutions and safeguard
consumers and investors assets by identifying financial crime, preventing fraud and providing regulatory
compliance. The company provides real-time, cross-channel fraud prevention, anti-money laundering
detection, and trading surveillance solutions that address such concerns as payment fraud, cybercrime,
sanctions monitoring, market abuse, customer due diligence and insider trading.
COMPANY CONFIDENTIAL
NICEACTIMIZE.COM INFO@NICEACTIMIZE.COM NICEACTIMIZE.COM/BLOG @NICE_ACTIMIZE LINKEDIN.COM/COMPANY/ACTIMIZE
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