Risk Management
Updated Sep 15th, 2023
Designed to be imported as extra tasks into existing work types. Covers ID Formalities and Client Due Diligence. Record client ID and complete your client and matter risk assessments as well as source of funds assessment within Osprey. Covers Individual clients as well as companies and beneficial owners. Client risk assessments are recorded at client level and will be available on any matter for that client ensuring that previous risk assessments are available. You can indicate if a client is a PEP and key dates allow you to ensure that ID expiry dates are never missed. A selection or reports allow you MLRO and COLP to ensure that expired ID and high-risk matters are monitored effectively.
Task 1 Client Due Diligence Risk AssessmentDisplay a message to the user
Please enter as much information about the Client(s) as you have available and rerun this workflow if further information becomes available. Please ensure that any pre-existing information is correct
Allocate a Custom Questionnaire
Client Risk Assessment Additional Risks
Allocate a Custom Questionnaire
Client 1 Additional Information (Criteria: CLI_IS_CO = No)
This Questionnaire repeats for Clients 1 to 5.
Allocate a Custom Questionnaire
Client Company Verification (Criteria: CLI_IS_CO = Yes)
Allocate a Custom Questionnaire
Client Risk Assessment – Beneficial Owner (Criteria: CLI_IS_CO = Yes)
Allocate a Custom Questionnaire
Client Risk Assessment – Beneficial Owner Risks (Criteria: CDD_CL_BEN_OWN = Yes)
Display a message to the user
Please enter the details of the beneficial owners on the following screens
Allocate a Custom Questionnaire
Client 2 Additional Information (Criteria: CLI_IS_CO = Yes AND CDD_CL_BEN_OWN = Yes)
This questionnaire repeats for benificial owners 2 to 5.
Display a message to the user
You may not accept a PEP as a client without approval from the firm’s MLRO.
(Criteria: CLI1_PEP = Yes OR CLI2_PEP = Yes OR CLI3_PEP = Yes OR CLI4_PEP = Yes OR CLI5_PEP = Yes)
Send Merged Email Template
Email to MLRO seeking permission to proceed with PEP client
(Criteria: CLI1_PEP = Yes OR CLI2_PEP = Yes OR CLI3_PEP = Yes OR CLI4_PEP = Yes OR CLI5_PEP = Yes)
Display a message to the user
Based on the answers to the previous questions it is likely that this client is a high risk. Please consider if EDD is appropriate
(Criteria: CDD_CL_ENG_WAL = No OR CDD_CL_GEO_RISK = Yes OR CDD_CL_COMP_STR = Yes)
Set Dossier Field
CL_CDD – CDD_CL_RISK – High Risk
(Criteria: CDD_CL_ENG_WAL = No OR CDD_CL_GEO_RISK = Yes OR CDD_CL_COMP_STR = Yes)
Allocate a Custom Questionnaire
Client Risk Assessment
Send Standard Document
Criteria: CLI_IS_CO = Yes
Meet unmet keydates by type
CLI_CO_ID (Criteria: CLI_IS_CO = Yes)
Add an automatic keydate to matter
CLI_CO_ID – Today + 3 Months – Renew Client CDD (Criteria: CLI_IS_CO = Yes)
Send Standard Document
Allocate a Custom Questionnaire
Client 1 ID Formalities
Client 1 Form of ID and Expiry are repeated for Forms of ID 1, 2 and 3.
Display a message to the user
Form of ID 1 has expired. Please ensure that the expiry of the ID is in the future. Please rerun the task and enter an expiry date in the future
(Criteria: CLI1_ID_1 “Please Select” AND CLI1_ID_1_VAL = “Expired”)
Display a message to the user
Form of ID 2 has expired. Please ensure that the expiry of the ID is in the future. Please rerun the task and enter an expiry date in the future
(Criteria: CLI1_ID_2 “Please Select” AND CLI1_ID_2_VAL = “Expired”)
Display a message to the user
Form of ID 3 has expired. Please ensure that the expiry of the ID is in the future. Please rerun the task and enter an expiry date in the future
(Criteria: CLI1_ID_3 “Please Select” AND CLI1_ID_3_VAL = “Expired”)
Display a message to the user
Please Ensure that you have saved any scanned ID proofs to the matter
Meet unmet keydates by type
CLI1_ID1
Meet unmet keydates by type
CLI1_ID2
Meet unmet keydates by type
CLI1_ID3
Add a keydate linked to dossier field
CLI1_ID1 – CLI1_ID_1_EXP + 0 Days – Client 1 ID 1 Expired (Criteria: CLI1_ID_1 “Please Select”)
Add a keydate linked to dossier field
CLI1_ID2 – CLI1_ID_2_EXP + 0 Days – Client 1 ID 2 Expired (Criteria: CLI1_ID_2 “Please Select”)
Add a keydate linked to dossier field
CLI1_ID3 – CLI1_ID_3_EXP + 0 Days – Client 1 ID 3 Expired (Criteria: CLI1_ID_3 “Please Select”)
Send Standard Document
Tick Task
Tick Task (Criteria: CLI1_ID_1_VAL “Expired” AND CLI1_ID_2_VAL “Expired” AND CLI1_ID_3_VAL “Expired”)
Allocate a Custom Questionnaire
Matter Risk Assessment Instructions
Allocate a Custom Questionnaire
Matter Risk Assessment Additional Risks
Display a message to the user
As the value of the case is likely to exceed the PI limit, please get permission to proceed
Criteria Is value of case likely to exceed PI max? = yes
Display a message to the user
Based on the answers to the previous questions it is likely that this matter will be high risk
Criteria
Unusually Complex Matter = Yes
or
Unusually Large Matter = Yes
or
Unusual Pattern of Transactions = Yes
or
No Apparent Economic or Legal Purpose = Yes
or
Property/assets in England/Wales = No
or
Is value of case likely to exceed PI max? = Yes
Set Dossier Field
CDD_MAT_RISK = High Risk
Criteria
Unusually Complex Matter = Yes
or
Unusually Large Matter = Yes
or
Unusual Pattern of Transactions = Yes
or
No Apparent Economic or Legal Purpose = Yes
or
Property/assets in England/Wales = No
or
Is value of case likely to exceed PI max? = Yes
Allocate a Custom Questionnaire
Matter Risk Assessment
Display a message to the user
Based on the answers to the previous questions it is likely that this matter will require Enhanced Due Diligence
Criteria
Unusually Complex Matter = Yes
or
Unusually Large Matter = Yes
or
Unusual Pattern of Transactions = Yes
or
No Apparent Economic or Legal Purpose = Yes
or
Property/assets in England/Wales = No
or
Is value of case likely to exceed PI max? = Yes
or
Client resident/based in England/Wales? =no
or
Any Geographic Risks Associated with the Client? = yes
or
Difficult to Identify the True Beneficial Owner = Yes
or
Any of Client 1 to 5 – Is a Politically Exposed Person? = Yes
or
Matter Risk = High Risk
Set Dossier Field
CDD_LEVEL_CDD – Enhanced Due Diligence
Criteria
Unusually Complex Matter = Yes
or
Unusually Large Matter = Yes
or
Unusual Pattern of Transactions = Yes
or
No Apparent Economic or Legal Purpose = Yes
or
Property/assets in England/Wales = No
or
Is value of case likely to exceed PI max? = Yes
or
Client resident/based in England/Wales? =no
or
Any Geographic Risks Associated with the Client? = yes
or
Difficult to Identify the True Beneficial Owner = Yes
or
Any of Client 1 to 5 – Is a Politically Exposed Person? = Yes
or
Matter Risk = High Risk
Allocate a Custom Questionnaire
Level of due diligence
Send Standard Document
Allocate a Web Questionnaire
Allocate Web Questionnaire – Source of Funds
Allocate a Custom Questionnaire
Source of Wealth and Funds
Allocate a Custom Questionnaire
Source of Funds
Criteria
Ascertained Source of Funds = Yes
Allocate a Custom Questionnaire
Source of Funds Gift Details
Criteria
Funds Contain Gift = Yes
Display a message to the user
You are required to obtain written confirmation from the person(s) making the gift, that the monies were a gift, that the monies are non-refundable and non-repayable and they will not have any interest in any asset being purchased
criteria
Funds Contain Gift = Yes
Send Standard Document