Sanction Screening process in AML KYC

Sanction Screening process in AML KYC

Sanction Screening process in AML KYC

Last Updated on Jun 05 2025, 2k Views

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Sanction Screening

Sanction Screening Process in AML/KYC is a critical component of a financial institution’s compliance program, aimed at preventing transactions with individuals, entities, or countries subject to economic or trade sanctions. Here’s a step-by-step overview of the Sanction Screening process:

1. Data Collection

Collect customer details during Customer Due Diligence (CDD) or Know Your Customer (KYC) onboarding.

Key data fields include:

Full Name

Date of Birth

Nationality

Address

Identification Numbers (Passport, PAN, etc.)

Business/Organization details (for entities)

2. List Aggregation

Sanction screening uses updated lists from official authorities like:

OFAC (U.S. Office of Foreign Assets Control)

UN Sanctions List

EU Sanctions List

UK HMT Sanctions List

Local regulators (e.g., SEBI, RBI in India)

Third-party list providers (e.g., World-Check, Dow Jones, Refinitiv)

3. Screening Types

There are two main types of sanction screening:

a. Customer Screening (Name Screening)

Performed during onboarding and periodically (Ongoing Due Diligence).


Checks customer names against sanctions lists.

b. Transaction Screening

Real-time screening of transactions (e.g., SWIFT messages).

Verifies that sender/receiver names, intermediaries, and involved countries are not sanctioned.

4. Matching Logic

Uses logic and algorithms to match names (considering spelling variations, aliases, transliteration).

Uses phonetic and linguistic rules.

5. Alert Generation

If a match is found, the system raises an alert.

Alerts can be:

True Positive: Legitimate match

False Positive: Non-matching individual/entity that appears similar

6. Alert Review and Escalation

Compliance analysts investigate alerts using:

Customer KYC documents

Additional screening tools

Public databases (e.g., news, registries)

Actions taken:

Escalate to MLRO (Money Laundering Reporting Officer)

File STR/SAR (Suspicious Transaction Report)

Block/hold transactions

Report to regulators

7. Ongoing Monitoring

Periodic re-screening of customers as part of Ongoing Due Diligence (ODD).

Sanction lists are updated frequently – systems must stay up-to-date.

8. Record Keeping & Audit

Maintain logs of:

Screening results

Decisions taken

Alert resolution process

Regulatory filings

Tools Used

Dow Jones Watchlist

Refinitiv World-Check

Fircosoft

LexisNexis Bridger Insight

Accuity

SAS AML

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AML/KYC Interview Questions: Advanced Preparation Guide (2025 Edition)

AML/KYC Interview Questions: Advanced Preparation Guide (2025 Edition)

AML/KYC Interview Questions: Advanced Preparation Guide (2025 Edition)

Last Updated on Jun 03 , 2025, 2k Views

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AML / KYC

AML/KYC Interview Questions: Advanced Preparation Guide (2025 Edition)

If you're targeting roles in Transaction Monitoring, Compliance, or Due Diligence — these 15 advanced questions will help you stand out in interviews

Top 15 Advanced AML/KYC Questions & Answers

1. What is FATF?

The Financial Action Task Force sets international standards to prevent money laundering and terrorist financing.

2. False Positive vs. False Negative?

False Positive: Genuine transaction flagged incorrectly

False Negative: Suspicious transaction that goes undetected

3. What is a Correspondent Banking Relationship?

When one bank provides cross-border services to another — considered high-risk due to lack of direct oversight.

4. What is a Beneficial Owner in KYC?

A person who directly or indirectly owns ≥25% of a legal entity or exercises control over it.

5. KYC vs. CDD?

KYC: Initial identity verification

CDD: Ongoing monitoring and risk assessment

6. What is Smurfing?

Splitting large illicit funds into smaller transactions to evade detection.

7. What is a Risk-Based Approach (RBA)?

Tailoring due diligence intensity to customer risk — focusing more on high-risk profiles.

8. Structuring vs. Smurfing?

Structuring: Breaking up transactions to avoid thresholds

Smurfing: Using multiple people to do so on behalf of one party

9. What is Trade-Based Money Laundering (TBML)?

Using trade (falsified invoices, mispriced goods) to conceal illicit funds.

10. What is an Ultimate Beneficial Owner (UBO)?

The individual who ultimately benefits from or controls a company, even behind layers of ownership.

11. What is Ongoing Monitoring?

Post-onboarding transaction and profile reviews to detect new risks.

12. Purpose of Customer Risk Rating (CRR)?

To classify clients as Low, Medium, or High risk and apply appropriate controls.

13. What is PEP Screening?

Identifying Politically Exposed Persons to mitigate corruption and reputational risk.

14. What is a Watchlist in AML?

A list of entities or persons flagged for sanctions, criminal history, or financial risk.

15. What is a Suspicious Activity Report (SAR)?

A confidential report filed with authorities to flag transactions that raise suspicion.

Save this guide if you're prepping for a role in AML, KYC, or Financial.

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How AML KYC work & what are the Different Process

How AML KYC Work & What are the Different Process

Anti Money Laundering

Last Updated on May 23 , 2025, 2k Views

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Anti Money Laundering

How Anti-Money Laundering Really Works (and why you should care)

AML isn’t just paperwork.

It’s a 24/7 defense system against financial crime.

Here’s what actually goes on behind the scenes:

1. Customer Due Diligence (CDD)

Basic ID checks

Verify address + source of funds

If you’re low-risk, you get the fast lane

2. Enhanced Due Diligence (EDD)

High-risk customer? Welcome to the deep dive.

Think: Politically Exposed Persons (PEPs), offshore accounts

More documents. More scrutiny. More time.


3. Ongoing Monitoring

Every. Single. Transaction. Is. Watched.

Spotted a weird transfer at 2 a.m.? That’s a red flag.

Patterns matter — not just one-offs.

4. Suspicious Activity Reports (SARs)

Something doesn’t feel right?

Compliance flags it + files a SAR

Goes straight to the regulators — no debate

5. Sanctions Screening

Global watchlist checks on every customer

Match a sanctioned entity?

Your account is frozen. Instantly.

6. KYC Refreshes

“Know Your Customer” isn’t a one-time event

Periodic updates (especially if risk increases)

New job? New country? New scrutiny.

Real Talk:

AML is not a checkbox.

It’s a living, breathing system that evolves with every risk signal.

Now imagine doing all this without automation?

(That’s why RegTech is booming.)

If you’re in FinTech, Compliance, or Legal—

You need to know this process inside out.

Top 5 Methods Criminals Use to Money Laundering

Top 5 Methods Criminals Use to Money Laundering

Top 5 Methods Criminals Use to Money Laundering

Last Updated on Nov 12 , 2024, 2k Views

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Anti Money Laundering

Money Laundering has become a massive problem for governments as the issue is escalating daily. It hits the world economy badly as the vast amount of money is used to fund illegal activities and fund terrorism. As per a recent UN report, approximately $ 800 billion – USD 2 trillion is laundered every year, accounting for 2-5% of global GDP. Anti-money laundering laws, rules, and regulations are implemented to detect suspicious accounts and transactions and trace the source of the illegal money. Now the question arises: what are the products and services that can be potentially used for money laundering activity, and how? So, let’s jump into it and discuss the top 5 methods criminals use to launder money and evade government scrutiny.

1. Instant Messaging

Who would have thought the instant messaging platform would become a popular choice for criminals to launder their dirty money? Criminals use instant messaging apps, which are more than messaging apps, and offer services that make payment facilities available.

Online transfers have reduced cash transactions to a great extent. With the vast amount of transactions being made on messaging platforms, tracking might be a problem, so businesses need to be vigilant and track down suspicious transactions and fake accounts. Companies will require resources and a team to identify such doubtful transactions.

AML training can help companies stay ahead of the criminals and know if the messaging platforms are misused. Training will equip them with updated knowledge of the technology being used and adopt a proactive approach to detect any suspicious transaction immediately.

2. Online Games

The online gaming industry today is growing by leaps and bounds. Criminals have found the gaming platforms to be a potential opportunity to launder money. The games use virtual currencies which users can trade for real cash.

There are no specific regulations for online trading in the gaming industry, so criminals set up numerous accounts in different jurisdictions to transfer money. They purchase in-game credits and transfer them to launder money. They also create fake accounts or hack existing accounts to steal other players’ credits, and all these attempts are made to increase the virtual currencies, which they can later trade for cash.

3. Gift Cards

Gift cards enjoy immense popularity. After the card is activated, criminals quickly transfer the funds available or use them to buy products sold for cash. Stolen debit or credit cards are rampantly used to purchase prepaid cards, and then they are further sold for money.

The method adopted by the criminals is to copy the serial numbers of the cards, scratch the security code and later cover them up. So, it’s essential to catch the criminals when the cards are stolen as these can be used to launder money. A method adopted to prevent prepaid cards for money laundering is that retailers limit the number of prepaid cards anyone can buy in a day

4. Cryptocurrency

Cryptocurrency is one of the most popular virtual currencies, and criminals are using this newest kid on the block to launder money. This digital currency is protected by encryption which prevents double-spending. But this currency is not issued by the central government and not regulated by the government, so they become a favourite method of the money launderers. Moreover, it is also banned in some countries.

For instance, the Chinese government has stated that all transactions in cryptocurrency are invalid. Though cryptocurrency may not pose a massive threat to a particular country’s currency, its increased use and entry into the mainstream medium of value exchange is undoubtedly something to worry about.

Today, the digital world is expanding, and many large-scale companies accept this modern currency for providing their products and services. So, it allows criminals to make transactions and indulge in financial terrorism. A recent study has revealed that approximately 56 % of worldwide crypto exchanges do not have a robust KYC process. People use this loophole and use digital currency to launder money.

5. Shell Companies

Criminals often use shell companies or front companies to launder money to hide the identity of the true beneficiary of the proceeds or the profit of the illegal activities. The modus operandi is to sell goods at discounted prices and show false profits. The legal and illicit money is mixed to make them appear legal and avoid scrutiny. This money is used to fund illegal activities.

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What is Placement in Money Laundering

What is Placement in Money Laundering

What is Placement in Money Laundering

Last Updated on Nov 12 , 2024, 2k Views

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Anti Money Laundering

Money laundering is all about hiding the source and nature of the illicit funds to make them appear as if they were obtained from some legitimate activities. The process of money laundering begins with the aim of disguising the original source of the criminal proceeds, and to do so, the illegal funds must be introduced first in the open economy. Placement is the first stage of money laundering where criminals use various methods like gambling, blending of funds, currency smuggling, etc., to introduce proceeds of crime into financial system.

What is Placement in Money Laundering?

A person who has received some ill-gotten gains will surely be on the lookout for measures to clean them in order to use them freely without any stipulations from regulators. So in order to use the funds, the criminal needs to disguise the source of proceeds to appear as the funds to be legitimate.


Money laundering involves a series of transactions to make its detection as difficult as possible. However, money laundering can broadly be classified into three stages.

1. Placement,

2. Layering, and

3. Integration.


The placement stage of money laundering involves the physical introduction of cash or other assets derived from criminal activity into the financial system. Criminals use various placement techniques like structuring, blending of funds, currency smuggling, etc., to commit money laundering.

Definition of Placement in Money Laundering

Placement is the first stage of money laundering, where dirty money is introduced into the financial system. It is the most vulnerable stage, and the chances of a criminal getting caught are the highest.

The goal of Placement in Money Laundering:

To hide the source of illicit money

To distance the money from its illegitimate source

To introduce dirty money into the financial system

The crimes like corruption, fraud, bribery, kidnapping, illegal arms trade, drug trafficking, smuggling, etc., are committed for money. Criminals obtain illegal proceeds, and then they try to find a way for their disposal without attracting the eyes of law enforcement.

Stages of Money Laundering

First: Placement Stage

The money launderer puts unlawful funds into circulation by depositing cash into the bank, executing any transactions to buy any luxury goods or using them in other legitimate businesses. This is the stage where the money launderer gets rid of illegal proceeds by placing them into the legitimate financial system.

The placement stage of money laundering is the most challenging for the launderer as the disposal of illegal proceeds by introducing them into the financial system causes suspicion.

Second: Layering Stage

Layering is the second stage of the three-step process. Under layering, the launderers make numerous transactions to distance the true owner and the source of illegal money, making it harder for the authorities to track. This can typically be as easy as using illegitimate funds to invest in something legitimate so that the funds now appear to be “clean”. Such funds are then transferred to purchase goods and services, making their detection nearly impossible.

Third: Integration Stage

Integration is the final stage of the money-laundering process. It is the stage where the disguised criminal proceeds are returned to and used by the money launderer, with a legitimate appearance given to the criminal proceeds.

When it comes to terrorist financing, integration is accomplished by distributing funds to terrorists and terrorist organizations.

Methods or Examples of placement in money laundering:

Smuggling illegitimate cash or liquid monetary instruments.

Blending unlawful proceeds with legitimate proceeds, such as illegitimate funds introduced into the

cash-intensive grocery business.

Repayment of debt using illegal proceeds.

Buying stored value cards with illegitimate money.

Depositing small amounts into several bank accounts to evade reporting threshold. It is also called smurfing, one of the most common money laundering techniques.

Buying foreign currency with illegitimate funds.

Cash purchase of a security or insurance.

Invoice fraud – over-invoicing or under-invoicing.

However, it is not always the case that criminals resort to the placement stage of money laundering. Criminals can use illegal proceeds for various purposes without resorting to money laundering. Black money can be used to pay salaries to partners in crime, bribery, etc.

The placement stage of money laundering is only relevant if the criminals have to introduce money to the legitimate financial system. If the black money is going to be utilized for other criminal activities, then the placement of funds will not occur.

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RPA Uipath

Robotic Process Automation

Last Updated on Aug 27 , 2024, 2k Views

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RPA uipath

RPA Uipath

UiPath is a popular Robotic Process Automation (RPA) platform that enables organizations to automate repetitive and mundane tasks, freeing up human employees to focus on more strategic and creative work. Here are some key features and benefits of UiPath:

Key Features:

Automation Studio: A visual interface that allows users to design and build automation workflows using drag-and-drop functionality.

Robot Operating System: A software platform that runs the automation workflow and interacts with the user interface.

Integration Framework: A framework that allows users to integrate UiPath with other systems and applications, such as CRM, ERP, and custom applications.

Object Recognition: A feature that enables robots to recognize and interact with objects on the screen, such as buttons, forms, and fields.

Machine Learning: A feature that enables robots to learn from user interactions and adapt to changing workflows and conditions.

Analytics and Reporting: Tools that provide insights into the performance of the automation workflow, including metrics on accuracy, speed, and volume.

Security: A secure platform that ensures data protection and compliance with regulatory requirements.

Benefits:

Increased Efficiency: Automate repetitive tasks, freeing up human employees to focus on more complex and creative work.

Improved Accuracy: Reduce errors and improve accuracy by automating tasks that are prone to human error.

Cost Savings: Reduce labor costs by automating tasks that are currently performed by human employees.

Faster Processing: Automate tasks faster than human employees, allowing for faster response times and improved customer satisfaction.

Enhanced Compliance: Ensure compliance with regulatory requirements by automating tasks that are prone to human error.

Scalability: Scale automation quickly and easily as business needs change. User-Friendly: Easy to use and configure, even for non-technical users.

Use Cases:

Data Entry: Automate data entry tasks, such as entering customer information or updating databases.

Document Processing: Automate document processing tasks, such as processing invoices, receipts, and contracts.

Customer Service: Automate customer service tasks, such as answering frequently asked questions or routing customer inquiries to the right person.

Accounting and Finance: Automate accounting and financial tasks, such as reconciling accounts or processing payroll.

Healthcare: Automate healthcare tasks, such as scheduling appointments or processing patient data.

Industry-Specific Use Cases:

Banking and Finance: Automate tasks such as account reconciliation, loan processing, and customer onboarding.

Healthcare: Automate tasks such as claims processing, medical billing, and patient registration.

Retail: Automate tasks such as order processing, inventory management, and customer service. Manufacturing: Automate tasks such as production planning, inventory management, and quality control.

Training and Support:

UiPath Academy: A comprehensive online training platform that provides training and certification for UiPath users.

Community Support: A community of UiPath users and developers who provide support and share knowledge through forums and online discussions.

Customer Support: Dedicated support team available 24/7 to provide assistance with implementation, configuration, and troubleshooting.

AML Question and Answers

AML Question and Answers

AML Question and Answers

Last Updated on Aug 06 , 2024, 2k Views

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Anti Money Laundering

1. What is Anti-Money Laundering (AML)?

Anti-Money Laundering (AML) refers to a set of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. AML policies focus on identifying and reporting suspicious activities to prevent financial crimes, including money laundering and terrorist financing.

2. Can you explain the process of money laundering?

Money laundering typically involves three stages:

Placement: Introducing illicit funds into the financial system.
Layering: Conducting complex transactions to obscure the origin of the funds.
Integration: Reintroducing the laundered money into the economy as legitimate funds.


3. What is Know Your Customer (KYC)?

Know Your Customer (KYC) is a process used by financial institutions to verify the identity of their clients. This involves collecting and verifying personal information such as name, address, date of birth, and identification documents. KYC is essential for assessing risk and ensuring compliance with AML regulations.

4. What are some common red flags in AML?

Common red flags include:
Large and frequent cash deposits.
Transactions involving high-risk jurisdictions.
Unusual patterns or sudden changes in account activity.
Structuring transactions to avoid reporting thresholds.
Use of multiple accounts to obscure the source of funds.

5. How would you conduct an AML risk assessment?

An AML risk assessment involves:

Identifying potential risks: Assessing customer types, products, services, and geographies.

Analyzing risks: Evaluating the likelihood and impact of identified risks.

Implementing controls: Establishing policies and procedures to mitigate risks.

Monitoring and reviewing: Continuously monitoring transactions and reviewing the effectiveness of
controls.

6. What is a Suspicious Activity Report (SAR)?

A Suspicious Activity Report (SAR) is a document that financial institutions must file with regulatory authorities when they detect suspicious activity that may indicate money laundering or other financial crimes. SARs help authorities investigate and combat illegal activities.

7. How do you stay updated with AML regulations and trends?

Staying updated involves:

Regularly reviewing regulatory updates from bodies like FATF, FinCEN, and OFAC.
Attending AML training sessions and conferences.
Participating in industry forums and professional networks.
Subscribing to relevant newsletters and publications.

8. Describe your experience with AML software and tools.

AML software and tools are essential for monitoring transactions, screening customers, and generating reports. My experience includes:


Using transaction monitoring systems to identify suspicious patterns.
Utilizing KYC tools for customer verification and risk assessment.
Working with SAR filing systems to report suspicious activities.
Leveraging data analytics tools to enhance AML investigations.

9. What steps would you take if you identified a suspicious transaction?

Steps include:

Conducting a preliminary investigation: Gathering details about the transaction.

Documenting findings: Recording all relevant information.

Reporting internally: Escalating the issue to the AML compliance team.

Filing a SAR: If deemed necessary, submitting a Suspicious Activity Report to the appropriate authorities.

10. Why do you want to work in AML?

I am passionate about maintaining the integrity of the financial system and preventing financial crimes. Working in AML allows me to use my analytical skills and attention to detail to detect and prevent money laundering activities, contributing to a safer and more transparent financial environment.

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AML Interview Question and Answers

AML Interview Question and Answers

AML Interview Question and Answers

Last Updated on Jul 22 , 2024, 2k Views

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Anti Money Laundering

1. What is AML, and why is it important?

AML stands for Anti-Money Laundering. It’s essential because it aims to prevent criminals from disguising the illegal origins of their money by making it appear as if it came from legitimate sources. AML regulations protect the financial system from being used for illicit activities.

2. Can you explain the KYC process?

KYC, or Know Your Customer, is a process by which financial institutions verify the identity of their clients to ensure they are who they claim to be. This involves collecting information and documentation, assessing risks, and monitoring transactions.

3. What are the primary objectives of AML regulations?

The primary objectives of AML regulations are to prevent money laundering, detect and report suspicious activities, and ensure compliance with relevant laws and regulations.

4. How does AML compliance relate to KYC?

AML compliance includes various processes, one of which is KYC. KYC is a subset of AML that focuses on identifying and verifying customers’ identities and assessing their risk levels.

5. What are the consequences of non-compliance with AML regulations?

Non-compliance can lead to severe penalties, including fines, reputational damage, and legal actions against individuals and organizations involved. It can also result in loss of business and regulatory restrictions.

6.Describe the AML regulatory landscape in [specific country/region].

The answer to this question will vary depending on the country or region you’re discussing. Be prepared to provide an overview of the AML laws, regulatory bodies, and recent developments.

7.What is the difference between AML and CFT (Countering the Financing of Terrorism)?

AML focuses on preventing money laundering, whereas CFT specifically targets the financing of terrorism. Both aim to prevent the misuse of the financial system for illegal activities.

8.What is the role of a Compliance Officer in AML/KYC?

A Compliance Officer is responsible for ensuring that an organization adheres to AML/KYC regulations and policies. This includes developing and implementing compliance programs, conducting risk assessments, and training staff.

9.How do you stay updated on changes in AML regulations?

Staying updated involves regularly monitoring regulatory websites, attending industry conferences, subscribing to AML news alerts, and participating in professional associations dedicated to AML/KYC.

10.Can you name some international AML regulatory bodies?

Some international AML regulatory bodies include the Financial Action Task Force (FATF), the Basel Committee on Banking Supervision, and the Egmont Group of Financial Intelligence Units.

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Transaction Monitoring Top Interview Questions

Home > Blogs > Transaction Monitoring Top Interview Questions

Transaction Monitoring Top Interview Questions

Transaction Monitoring Top Interview Questions

Last Updated on Dec 18 , 2023, 2k Views

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Transaction Monitoring

1.What is Transaction Monitoring?

Transaction Monitoring is a process of reviewing the transactions of the customer to identify if there are any suspicious transactions and recommend SAR (Suspicious Activity Report) {Tool used in Transaction Monitoring by most banks is Actimize)

2.What is SAR/ STR/ SMR?

SAR (Suspicious Activity Report) or STR (Suspicious Transaction Report) or SMR (Suspicious Matter Report) is a tool used by financial institutions to file suspicious activity to the FIU (Financial Intelligence Unit).

3, Tell me about a few thresholds?

- Rapid Movement of Funds/ Wash Transactions
- Structuring of funds
- Large Incoming of funds
- Large Outgoing of funds
- Negative Keyword
- Burst in customer activity
- Round dollar amounts

4.Tell me about Rapid movement of funds?

Rapid movement of funds is quick incoming and outgoing of funds within a week’s time, also known as wash transactions.

5. Tell me about Structuring of funds.

Structuring of funds are transactions which fall below the reporting threshold, for example in the US, transactions below 10000 USD fall under the structuring pattern. *Structuring is a process of breaking a large amount of funds in smaller transactions below the reporting requirement to avoid regulatory reporting.

6. Tell me a scenario where you had identified a potential Suspicious activity?

There was a case that was closed by the operations team based on complimentary line of business, but when it came for QA review, I was able to identify through open search that the focal entity had a subsidiary in Iran, which is a Sanctioned country, and hence we reopened the alert and escalated to Level 2 team, and later during the onsite calibration call, it was informed that a SAR has been raised on the FE, and I received an appreciation from the US stakeholder.

7. Who is the India, US and UK financial regulator?

- RBI – Reserve Bank of India
- OCC – Office of the Comptroller of Currency for US
- FCA – Financial Conduct Authority for UK

8. What is BSA Act?

BSA Act also known as Bank Secrecy Act of 1970 states that financial institutions should record and report financial transactions. BSA Act has five pillars, which every financial institution should implement – 1) Development of internal policies and procedures; 2) Appointment of designate compliance officer; 3) Employee ongoing training program; 4) An independent Audit review; 5) Customer Due Diligence

9. What is the full-form USA Patriot Act?

- USA Patriot Act of 2001 also referred as “United and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism”.

-Section 313 – refers to prohibition of doing business with shell banks.

-Section 314 (a) – refers to sharing information with law enforcement and regulators. 314 (b) – refers to sharing information with other financial institutions.

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KYC and Screening Top Interview Questions

Home > Blogs > KYC and Screening Top Interview Questions

KYC and Screening Top Interview Questions

KYC and Screening Top Interview Questions

Last Updated on Dec 18 , 2023, 2k Views

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KYC

1.What is KYC and key elements of KYC? (Interviewer may not ask for whole answer mentioned below, but may ask in bits and pieces)

KYC (Know your customer) is a process of knowing the customer details. KYC process involves six key critical components provided below-

1) Identity and Verification (ID&V) –
In this bank collect the identity information of the customer. (If individual, banks collect ID and Address verification document; and if company, bank collects document like Articles of Association, Memorandum of Association and Incorporation Certificate, Beneficiary Ownership Certificate, Recent audited financial statement, for Partnership companies – Partnership deed/ for Trust – Trust deed); to prove legal existence of company; status of the company; date of incorporation; registration number; entity legal name.

2) Customer Profile –
In this step, bank identifies (for Company) - ultimate beneficial owner (UBO); - nature of business (including identifying primary supplier and dealers and their operational activities to make sure no sanctions risk involvement); - nature of relationship to be established with the bank (including understanding the amount and volume/ number of expected transaction in a period of time); - SOF & SOW- Identification of source of funds and source of wealth; - Key Individuals or Principals (basically, a CEO, CFO and COO of the company). (for Individual) – Customer type (normal, HNI or PEP); - Employment details; - nature of relationship to be established with the bank; - Identification of source of funds and source of wealth.

3) Screening-
In this step, Customer name is screened through three types of screening, 1) Negative media - (Tools used - World Check/ Factiva) – to identify negative news; 2) Sanctions screening (tool used- Actimize) – Customer name is screened against the SDN list; 3) PEP screening (tool used- Actimize) – Customer name is screened against the PEP list.

4) Risk Rating & Acceptance –
In this step, Customer risk is determined based on three primary factors, 1) Customer type; 2) Geographical Risk; & 3) Product type & Industry, and is accepted with relevant risk of High, Medium or Low.

5) Monitoring and Investigation – In this step, banks monitor the unusual transactions or pattern, and appropriate investigation is done to understand the purpose of the transactions deviating from the customer KYC profile.

6) Documentation- In this step – Bank documents the finding for the investigation as evidence of investigation performed.

2.What is customer KYC review/ KYC Refresh?

1) Periodic Review and 2) Event based KYC Review. In Periodic review, for Low-risk customer – every 5 years review is performed, for Medium risk customer – every 3 years review is performed, and for High risk customer – every 1 year review is performed. In Event based review/ Event Driven Review – KYC review is performed, whenever customer transactional/ business activity/ geography deviates the KYC of the customer.

3.What are corporate registries, and name a few?

Corporate registries are government website which has centralized information of corporates registered under their jurisdiction. Few corporate registries are as mentioned below –
For India – MCA (Ministry of Corporate Affairs)
For UK – Company House
For US – SOS (Secretary of State) + State name

4.What is EDD and why bank perform EDD?

EDD is Enhanced Due Diligence, which is performed on high-risk customer, to mitigate the higher risk the customer may bring to the bank. The risk is mitigated by doing additional due diligence like, doing site visits to verify the customer existence, verifying banking reference, calling and email on the provided details to check whether they are actually assigned, verifying the financial documents of the entity and all other steps involved in customer due diligence.

5.What is “Ultimate Beneficial Owner” structure threshold percentage for Low, Medium and High-risk customers, while doing KYC profiling?

For Low and Medium risk customers, any UBO holding 25% or more ownership in a company will undergo KYC process. For High-Risk customers, any UBO holding 10% or more ownership in a company will undergo KYC process.

Screening

1.What are Sanctions?

Sanctions are trade and official restrictions imposed to economically disable those who are involved in committing illegal activities and have broken the international law impacting human rights. Sanctions are imposed by global bodies like the UN (United Nations), EU (European Union), Interpol, OFAC (Office of Foreign Asset & Control) in the US, HMT (Her Majesty’s Treasury) in the UK and others.

2.What are the types of Sanctions?

There are three types of sanction screening

1) List/ Target Based Sanctions - list based sanctions will have names of individuals also known as (SDN Specially Designated Nationals), organizations and vessels (mostly ships).

2) Sectoral Sanctions – Sanctions imposed on certain sector of an economy/ country (for example – Financial sector, Defence Sector and Energy Sector of Russia is sanctioned)

3) Comprehensive Sanctions – These are complete sanctions imposed on countries to disable economic strength, by restricting trade relations. Examples of comprehensive sanction countries are, Iran, North Korea, Syria, Cuba, Crimea Region

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