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55 Cards in this Set

  • Front
  • Back

Key Operating Standards,


KOS

File of knowledgeable insights into the KYC process

CLM, Client Lifecycle Mangament

The processs of new client adoption to regular review and exiting

Types of processes in KYC

New client adoption


Regular review


Event driven review


Cross jurisdictional divisional adoptions, CJDA


MUlti-Jurosdictional adoption


New product extension

Four eye review

Checker, second person

Roles in KYC

Business unit heads - accountable for ensuring their division adheres to the KYC policy.


Accountable client owner


Business senior manager - Above ACO


CLM Client on boarding


Head of anti financial crime


SOE

State owned entity

Db recognized regulated entity

Partially or fully traded on a Db recognized stock exchanges

Db recognized branch

The entity itself is owned by a company traded on a Db recognized exchange

SPV , spécial purposes vehicle

Corporate body to fulfill narrow or specific objectives

PIV private investment vehicle

Setup by a single or group of individuals for the sole purpose of investing their wealth

CRR , client risk rating

Assigned at initially NCA and again at RR and EDR


low medium or high

CRRM, Client risk rating methodology, 5 pillars

Country, industry , product , entity type , delivery channel


Delivery channel - how does the money get from us to them

Plausibility check

Determine whether ownership and controls structure is credible and in line with expectations

Validation

Check information given against public and private information

Normal business activity

SoF term, basically normal, okay wealth based on information, income

CSM, client senior managers

Natural or non natural person show holds special executive powers. Identified using IDV matrix

UBO, ultimate beneficial owner

Person at entity who holds a percentage of entity or a natural person on whose behalf a transaction is being conducted

Common


Preferred


Bearer shares


Family and group ownership


Nominee shareholder

Preferred shares have no voting rights


Bearer shares - no record of ownership is maintained by the issuing company


Nominee shareholder legal owner acting in a nominee capacity

ACO accountable client owner

People at DB in charge of a client

Ownership chart

Can be requested form entity


Different group of people and their ownership


Two methods to determining methodology - accumulation and domination

NLS, name list screening

Screening against sanctions , terrorist lists, adverse media, internal DB lists of unwanted individuals

Ficrosoft

NLS software

Group Review

Performed when a client subject to RR is part of a group of clients of the bank

AAR, account activity review


EDR , Event driven review

AAR, scrutinizing product usage and account behavior Over a time period


EDR, an event that triggers a review

One off transaction

Single exchange, not onboarded as client but required for specific due diligence

MSB, Money Services Business / FinTech

Natural or non natural person undertaking business in


Currency dealings


Chèque casher


Money transmitter


Issuers or traveler checks


Payment aggregators

Correspondent relationship

Banking services to institutions which are themselves providing banking services to their own clients

Syndicated lending or secondary loan trading

Term loans letters of credits ,


Involves one or more institution contracting to provide credit to a group.


secondary loan trading - trading activity following completion of syndicated loan trading.

Correspondent banking

Provision of banking services by one bank (correspondent ) to another (respondent ) bank

CIS, collective investment scheme

Mutual funds, hedge funds, private equity funds

NCA,


Principal vs Agent

Principal - assets belong to the client


Agent - transacting for the benefit of one or more UPs , underlying principals. Assets involved belong to the UPs not the agent.

Identification

Identifying CSMs for example

Vérification

Process of confirming the accuracy of this information based upon reliable information sources.

Underlying principal (UP)

When a client is acting as an agent is transacting for the benefit of one or more UPs

Principal vs Agent clients

Principal is a client acting on its own behalf and it’s own benefit


Agent - transacting for the benefit of one or more UPs

Guarantor

Guaranteeing a loan, are subject to KYC requirements of a client when Db is acting as a lender.

Intermediary

All people involved in establishing a client relationship. Introducing business or clients.

Distributor or arranger

Account holders with DB that plan to distribute Db products.

Nature of business and purpose of relationship

Why are they dealing with DB and how will the products be used? Are the services provided in line with the understanding of the nature of the business and purpose of the relationship.

Nature of business

Refers to the clients activity and profile , - nature of primary operations (banking , construction )


Legal structure


Products and services offered by client

Db recognized listed entity

Entities that have some or all of their share capital admitted to trading on a DB recognized stock exchange

Private entity

Not listed on a Db recognized exchange

ID&V

Identification and vérification

TCC True Copy Certification

True copy, reproduced from original


Certified true copy - true copy authenticated by a reputable third party or DB staff

CJDA

Adoption of an existing client that wants to extend its business with the bank to another jurisdiction or division -


Jurisdiction example - Singapore

Material trigger event

Increases risk rating , EDR


Material meaning something of importance

Partial trigger event

Doesn’t result in increase to the financial crime risk

Insolvency

Bankruptcy

PoA

Power of attorney - acting on behalf of persons engaging in one off transaction are treated as clients and are subject to due diligence.

Split transactions


Linked transactions

Split- full amount is divided by transaction


Linked- two or more transactions linked by inherent characteristics

IBO


Intermediate Beneficial Owners

Natural or non natural person indirectly or directly owns or controls any part of a prospective client. More than 25 %

BSF - Business Sponsorship Form

Form that business submits to CLM with info to help determinining client risk classification

Adverse information

Negative info on a entity

Business

Distinct body within the bank characterized by a particular type of client or market segment

Business sponsor

DB employee who proposes that the client should be adopted