Features of customizing AML/KYC policies and procedures to the needs of a specific client

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A specialist in the practice of migration and corporate law, he also specializes in legal support for business in EU countries.

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Features of customizing AML/KYC policies and procedures to the needs of a specific client

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AML (Anti-Money Laundering) and KYC (Know Your Customer) are key aspects of financial regulatory policy that are becoming increasingly important in today's regulatory context.

The characteristics and needs of each client may be different, so customizing AML/KYC policies and procedures to their individual needs becomes necessary in today's world of finance.

The essence of AML/KYC

AML/KYC sets out the standards that financial institutions must meet to ensure that financial systems are detected and prevented from being used for money laundering and terrorist financing.

These processes typically include identity verification (KYC), identification of the source of funds, and monitoring of financial transactions to detect unusual or suspicious transactions.

The need for customization

  • Diversity of customers

The diversity of customers lies in their unique needs, risks, and circumstances. For example, legal entities may have complex ownership structures that require detailed analysis and verification.

Such clients may have many business partners or branches in different countries, which requires additional attention to identify possible risks. On the other hand, individuals may have various sources of income, such as salary payments, investments, pension payments, etc.

Taking into account these unique characteristics allows us to approach each client individually and adapt AML/KYC procedures according to their needs.

  • Sector specifics

Different industries have their own characteristics and risks. For example, financial institutions dealing with large sums of money are more likely to be at risk under AML/KYC requirements compared to other industries such as retail or manufacturing.

Financial institutions may have more stringent customer identification, transaction monitoring, and reporting requirements due to their high exposure to regulatory risk. While other industries, such as real estate or IT, may have lower risks and less stringent requirements for AML/KYC procedures.

Understanding these sector specifics helps determine which aspects need attention and adaptation for each client.

  • Geographical factors

Different regions have their own unique risks and regulatory compliance requirements. For example, countries with high levels of corruption or low levels of financial stability may have an increased risk of money laundering and terrorist financing.

Customization of AML/KYC policies may take into account these differences in regulatory requirements and require additional verification procedures for customers who have business connections or transactions in these regions.

Some regions may also have specific AML/KYC regulations and restrictions that require a customized approach to clients doing business in those regions.

Taking these factors into account allows you to ensure the effectiveness and relevance of AML/KYC policies and procedures, and also reduces the risk of using financial systems for fraudulent activities and illegal purposes.

The customization process

  1. Risk analysis

Before starting the process of customizing AML/KYC policies, a risk analysis must be performed. This analysis includes an assessment of the potential financial, reputational, and legal risks associated with a particular client.

This may include an analysis of their business reputation, history of financial transactions, territorial exposure, and other factors that may affect the level of risk. Based on this analysis, it is possible to determine the level of integration risk, as well as the need for additional control measures.

  1. Determining the client's needs

After analyzing the risks, it is important to understand the needs and characteristics of a specific client. This includes understanding their business model, industry, location, and strategy.

For example, legal entities may have different compliance and control needs than individuals. Understanding these needs helps to develop customized approaches to AML/KYC procedures and customer convenience.

  1. Development of adapted procedures

Individualized AML/KYC procedures are developed based on the analysis of risks and client needs. These procedures may include specific requirements for identity verification, conducting additional investigations into sources of funding, and establishing monitoring of financial transactions.

For example, more stringent screening procedures may be established for high-risk clients, including additional checks on funding sources and periodic monitoring of financial transactions.

  1. Constant monitoring and updating

AML/KYC policies and procedures should be continuously monitored and updated to reflect changes in client risk and regulatory requirements.

This means that policies and procedures should be regularly reviewed and adapted, taking into account changes in customers' business models, their risks, and changes in the regulatory environment.

Such constant monitoring and updating allows us to ensure the effectiveness and relevance of AML/KYC procedures by changing conditions and customer needs.

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Head of International Corporate Law and Fintech Practice

A specialist in the practice of migration and corporate law, he also specializes in legal support for business in EU countries.

Contact now
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