Depending on how a firm has set up OnePractice to meet requirements (based on the firm’s Risk Assessment and Compliance Programme), various actions will trigger to warn that Due Diligence is required for that party. Parties where OnePractice believes Due Diligence is required display a red warning, see figure 1.
Figure 1
Client ID and Proof of Address documents should be scanned and managed into client level documents.
To record AML/CFT due diligence information, follow the steps below.
Setting the On-Boarding Method
Each party that requires Due Diligence to be completed requires the type of on-boarding method used to be selected from a drop down of firm determined, pre-populated codes. (Setting the types of on-boarding is covered in this manual in the Various AML Related System Codes.)
Under the AML/CFT CDD tab on the party click the Edit button, see figure 2.
Figure 2
The edit party screen will open, on the AML/CFT Requirements tab, see figure 3. Select the required on-boarding type from the list.
Figure 3
Setting the Nature and Purpose
In the same area as setting the On-Boarding method, see figure 4, the details relating to the nature and purpose must also be completed. This is a text box field, use the green plus to add.
Figure 4
The nature and purpose can also be set when creating a new matter for an existing client in the Edit Matter screen, see figure 5.
Figure 5
Any existing nature and purpose records will be displayed, and a new nature and purpose added. (Note that existing nature and purpose records will not be deleted).
Setting the Risk Rating
In the same area as setting the On-Boarding method, see figure 6, a Risk Rating must be set (legislation effective from 1 June 2025). Use the green plus to add, then choose from the dropdown list (NOTE Risk Ratings are set up by firms in accordance with their own specific Risk Assessment and Compliance Programme - see our article on AML/CFT Codes to Set Up here)
Figure 6
A comment as to the Risk Rating must also be provided.
Figure 7
Setting the Politically Exposed Person (PEP) Status
Details relating to the results of the Politically Exposed Person (PEP) Status can be recorded under the AML/CFT Requirements tab for all Individual type parties.
As a PEP Status only relates to individuals, this setting is only available to be set on individual party types. If a client is a Trust, the PEP Status is not applicable, however the PEP Status is applicable on any individual trustees. If a client is a Company, then again, the PEP Status is not applicable, however the PEP Status is applicable on individual Directors and Shareholders.
Utilising the Affiliated Parties option on each party allows this information to be captured, see the Affiliated Parties section of this manual for further details.
To set the PEP Status on individual parties, select Edit Party, under the AML/CFT Requirements tab click the “Set” button, see figure 8.
Figure 8
See figure 9 for the options.
Figure 9
Any party that is found to be a PEP will require approval from the appropriate AML Compliance Officer, Director, or Partner at a firm in accordance with the firm’s Compliance Programme. (Figure 10 below)
Figure 10
Setting the Source of Wealth / Source of Funds of Enhanced Due Diligence
Party types that have been set to require Enhanced Due Diligence (EDD) i.e., Trust type parties, will display an additional field for the Source of Funds to be noted, under the AML/CFT CDD tab, see figure 11.
Figure 11
Any party, where after consideration EDD is deemed to be required (over and above standard due diligence requirements) can be set so that the additional required information is captured. This is done in the Edit Party screen under the AML/CFT Requirement tab. Set the CDD level required to Enhanced, see figure 12.
Figure 12
Adding a Due Diligence Record
A Due Diligence Record needs to be added to the party to record the details and findings of the Due Diligence, whether it be completed or underway but perhaps delayed. Firms may decide to add a Due Diligence record at every step of the customer on-boarding process, so that if a DIA audit were to occur, the records would show the firm to be thinking about their clients and getting to know them.
To add a Due Diligence Record to a party, select the AML/CFT CDD tab and click the green plus icon under the Due Diligence Records section of the screen, see figure 13.
Figure 13
Figure 14
Complete the details as required (see figure 14) and then save the record once completed.
The level of diligence required should be correct, however this can be altered to suit.
The Status options are pre-determined by OnePractice.
The Due Diligence Result Codes are defined to suit the requirements of your firm.
These result codes allow the AML Compliance Officer to search the system to review CDD on the firm’s parties.
The Comments box allows to any additional text information that may need to be recorded.
Figure 15