Anti-money laundering checks
How anti-money laundering checks work
The checks a client goes through before you accept them and while they stay, who decides each one, and what they cost.
Your business is responsible for knowing who it acts for. Orin OS takes each client through a set of anti-money laundering checks before you accept them, and keeps two reviews running for as long as they stay. This article explains how the pieces fit together; the articles linked below show how to do each one.
These checks are for accounting practices. If your business is not set up as one, the AML screens say so and offer nothing to run.
The checks, in order
- Add the client. You record who the client is and everyone whose ownership or control matters.
- Screening. Every person is checked against sanctions lists and for politically exposed persons. A business is checked against sanctions lists only. A screen is never taken on trust from an earlier one.
- Verify identity. Each person receives a link and proves who they are. You can also check the business itself.
- Accept the client. You confirm the declaration, and the acceptance record is closed.
- Ongoing reviews. A due-diligence refresh and a re-screen recur while the client stays.
Who decides
Most of the work is done by whoever is adding or looking after the client. Two kinds of decision belong to your money laundering reporting officer (MLRO) and nobody else:
- whether a possible screening match is a real match;
- whether an identity check that was referred or failed should be treated as passed or as failed.
Name your MLRO in Business details. If nobody holds the role, a possible match cannot be ruled on and the client cannot be accepted.
Which clients wait for an identity check
A client you add as New to firm cannot be accepted until every person whose ownership or control matters has passed an identity check, or the MLRO has accepted their check. The check on the business itself is offered but never required.
A client you carry across as Existing client does not wait for identity checks, because it was accepted before. You can still run a check on anyone.
If no identity check can be run at all, for example because the identity service is unavailable, you can go on without one. The client is then marked as not identity-checked, and your MLRO is told.
What the checks cost
Identity and company checks are paid from your business's AML wallet. When you request checks, their cost is held from the wallet straight away and charged as each check finishes. Whatever is not used, for example because you cancel a check, is released back to the wallet.
Where to find it all
- A client's Compliance tab holds its acceptance record, AML reviews, screening and identity checks.
- Reports, then AML reviews, lists reviews that are overdue or coming due across every client.
- Settings, then AML wallet, shows the balance and lets you top it up.
Next steps
- Identity checks: request a check and read its result.
- AML reviews and re-screens: keep a client's reviews up to date.
- Adding a client: the acceptance steps in full.
Common questions
Can anyone in the business rule on a screening match? No. Only the MLRO can. Everyone else sees that the match has been sent to them.
Does a passed check ever change? No. Every check is kept, and a result is never rewritten. The MLRO can only record a decision beside it.
Do these checks replace our own judgement? No. They record what was checked and when. The risk rating and the decision to accept a client remain your business's.