The Customer Profile

When creating a new customer or altering an already existing customer, the profile as shown in the figure above would be presented to you - either in an empty state for new customers or in a filled in state for already created customers. 

Note that the entity above reflects a Legal Entity and therefore has the Shares and the UBO Chart tab which would not feature within a Natural Person type entity.

The customer profile is segregated in different sections, better aiding you in focussing on the areas that require your attention. These sections are:

• Details: Providing a detailed overview of the main client, depicting what type of entity the customer is.

• Involvements: Providing a detailed overview of all involvements that form part of the main client.

• Shares (for Legal Arrangements only): This section shall provide the user with a tree structure on how the involvements are linked to the main client, also exposing involvements that are also Legal Arrangements which would have their own shareholding structure and set of involvements. This section would be used to purely instruct KYCMATIC on how how many shares are owned by every party which is associated to a legal arrangement - either being that of the main client or of any other involvement who is also a legal arrangement.

• UBO Chart (for Legal Arrangements only): Provided the Shares are correctly entered, KYCMATIC would build a UBO chart which would be viewed in this area. 

• Screening: The process of screening and the discounting of hits is a vital and key process as part of CDD. This area is dedicated to just that. Screening would occur on the main client as well as all involvements. 

• Documents: As part of the customer profile, documents is another crucial part of KYC. This area is therefore used a document repository for your main client and the involvements which shall enable you to record any related document which required of CDD. Furthermore, KYCMATIC also stores a history of documents per document which would have been uploaded which may be viewed at any point in time during the relationship. 

• Activities: The scope of having a customer is to provide them with at least one service. This area shall therefore house the different services a customer would be making use of from your firm. 

• Risk Assessment: An area providing you with the facility to ask certain questions (based on your process) which may increase the risk and/or raise a task provided that the output of this question is set to 'Yes'. This area is typically used by subject persons who wish to capture more information on their client. 

• Risk Analysis: One of the main objectives of the KYCMATIC solution is to provide you with granular risk information about all entities who form part of your customer cohort, per risk factor pillar as well as providing the final CRA after all the Risk Score configuration and weightings have been applied. 

• Report: The final section of the customer profile is the report which shall provide a consolidated report on the customer, their services and all other information available.

Further information on the different areas are defined below. 

Details Tab

Involvements Tab (Not available for Remote or Land Based Gaming)

As the 'Details' tab is solely dedicated towards the details of the main client, the 'Involvements' tab is solely dedicated to the involvements that form part of the legal entity (being the main client). 

(Please note that with regards to natural persons being the main client, the involvements tab would still be present, albeit within the activity module since certain entities may have a PoA representation for specific services, therefore capturing this information on the PoA within the involvements area). 

Within this section, users are able to construct the structure by filling out the details for every involvement that form part of the main client, whether they are that of a natural person or a legal arrangement. Inevitably, for every legal arrangement (who are associated in one way or another with the main client), their respective involvements would be constructed and built. 

It is imperative to note that every involvement must be assigned an 'Involvement Type', such as Director, Shareholder, Representative, etc which would indicate their role in the legal structure. 

Shares Tab (Only Shown for Legal Arrangemetns)

As you would have built the involvements in the previous tab, provided the structure is accurate, the 'Shares' tab would represent the structure you would have built between the main client and their involvements. which is represented in the left part of the frame. Here, for every Legal Arrangement (therefore, for the main client and other involvements which are that of a Legal Structure), you would be able to set the shareholding per entity - which is achieved in the right part of the frame. 

As you can see between the two different figures above, KYCMATIC may handle different share structures. As some legal arrangements may solely have ordinary shareholding and one type of share, others may have different types of shares which would include the element of voting rights.

You may therefore able to create different types of shares per legal arrangement and state what share has voting right - thus adding more weight to when KYCMATIC would identify the Ultimate Beneficial Owner. 

UBO Chart Tab (Only Shown for Legal Arrangemetns)

Once the shares would have been entered within the 'Shares' tab, KYCMATIC would instantly go ahead and automatically generate a structure chart based on the information that was provided.

From a % perspective on who is considered a UBO, the default criteria is that an entity is considered to be a UBO when either:

• The Ordinary shareholding is 25%+1 share, or when;

• The amount of voting rights exceed 25%

Nonetheless, this % is configurable per environment and may be altered with Diligex's guidance and input. 

Therefore, depending on this logic, the UBO chart is built and depicts per entity their % of shares (for any form of share type - whether they are ordinary and/or that of voting rights) per entity that fall part of the structure chart.

Screening Tab

Screening is one of the more imperative actions which must be conducted as part of the AML process. KYCMATIC offers screening functionality which is directly in-built into the solution, providing initial and ongoing screening on any entity throughout the business relationship. 

The screening tab found within the customer profile shall provide the user with the main client as well as a list of the involvements (and sub involvements) that form part of the main client (if any). 

For very entity, the screening checks would be provided enabling the compliance user quickly identify if there is anything of concern in relation with the entity from a screening/searches perspective. 

Selecting the 'Screen' icon shall direct the compliance user to the Screening module to action and conduct the screening. More on this is described and explained in 'Screening an Entity'

Documents Tab

The proof of what a client mentioned is predominantly defined by what documents they can provide which justifies their claims. KYCMATIC therefore also acts as a document management solution enabling the compliance team consolidate and organise all client related documents within the KYCMATIC solution. As explained and outlined within the 'Customer Dashboard' page (in the Documentation section), documents may be uploaded (or sent through the API) for any entity, being able to process the document, review historic versions of the document as well as conduct a manual Identification & Verification between 2 or more documents available for the entity. 

Conducting Manual Identification & Verification

KYCMATIC enables compliance users conduct manual identification & verification on an entity through the use of documentation that had been provided by the entity. Such documents would typically be Identification documents, KYC forms or Utility bills from established and known entities. 

Selecting the 'Conduct I&V' button shall provide the compliance user a screen similar to the above figure. Once here, the user is required to select one or more source documents (using the drop down on the top left) and one or more verification documents (using the drop down on the top right). 

As the documents from the respective drop downs are selected, the documents would load in their respective frames as shown in the above figure. Once loaded, the compliance user would be able to answer the questions on the left by comparing the information between one document and another. 

Answering all the questions and selecting save would finalise the process of the identification & verification on the entity.

Activities Tab

The activities tab shall enable the compliance user review a list of Products & Services the entity is making use of - as well as information specifically related to that particular product & service. With the exception of Remote Gaming and Land Based Casinos, the details of the activity will provide imperative information on that particular activity in conjunction with the client. On the other hand, when it comes to Remote Gaming or Land Based Casinos, despite having these features available within the activity, the 'Events Module' would be the primary focus and the module which would be of most use to better understand the trends of a player in relation with their transactions. More on this can be found within the 'Remote Gaming & Land Based Casino Events' section of this user manual. 

Selecting the 'Unlink' button would unlink this activity from the customer - as though the customer is now not making use of this activity. Typically this would only done provided that the activity was created and/or associated with the customer in error. Otherwise, if not, any activity that wished to be made use of by the customer would either be Accepted or Declined - yet still linked to the customer, being able to identify what type of Products & Services the customer had made use of and/or wished to have made use of. More on this is explained within the 'Activity Module' section of this user manual.

Selecting the 'Go To Activity' button shall direct the compliance user directly to the Activity within the activity module which is further explained within the 'Activity Module' section of this user manual.

Finally, assuming the compliance user would have altered information within this screen, selecting the 'Save' button would save the newly entered data and therefore update the activity details. 

Risk Assessment Tab

The Risk Assessment tab is purely there to enable the MLRO provide a list of questions to Diligex to place in this area. This is solely to be used to enable the MLRO to ask for more information based on their process, by asking questions which would be a yes or no answer. 

Provided that the answer is yes, the risk of the entity may be increased and/or a task may be raised.

Risk Analysis

Customer & Entity Risk Analysis

The scope of the Risk Analysis Tab is to amalgamate the risk score configuration (described in the 'Configruation & Setup' section) and the inputted information on the entity which would provide the compliance user with a final Customer Risk Assessment.

Furthermore, KYCMATIC aims to provide the compliance user with a risk per risk factor pillar individual, therefore being able to identify what type of information would have pushed the risk higher (if at all). 

Associated Products / Services Risk Analysis

The Products & Services Risk Factor Pillar is placed on its own within a sub area since this section shall contain all the products & services the customer would be making use of, as well as their associated service type risk. 

Overriding of Main Customer Risk

Needless to say, there may be circumstances whereby the MLRO would require to override the CRA being provided by KYCMATIC. To do this, the MLRO (typically, solely the MLRO would have such rights to perform such a task) must select the main client risk - in this case being the 'High' risk pertaining to 'Microsoft Ireland' (used as an example for this manual) - which when selected, the MLRO would be prompted with a screen similar to what is shown in the above figure. 

From this screen, the MLRO would be able to alter the risk and would also be required to enter a reason to why the risk is being altered - which would be kept within the audit trail. 

It is important to note that although the risk is overridden, KYCMATIC would still store the original risk that it had originally outputted. 

CRA Calculation & Workings

KYCMATIC shall also be able to provide you the workings on how the CRA has come about for the main client. Hovering over the risk shall provide a tooltip as shown in the figure above. 

Based on the risk score configuration and overall weightings as described in the 'Configruation & Setup' section, the tooltip would provide the calculations which shall aid the compliance user in understanding the methodology for the specific entity. 

Report Tab

The report tab shall feature all information throughout the customer profile in a reporting format which may be printed to PDF.