Get the sponsor bank’s pre-approval before activating a high-risk customer

KYC / CIP / KYB policy, §5

A Tier 3 customer is not activated until the AML Compliance Officer has approved a written risk memo and the sponsor bank has given written pre-approval. Before the first customer of a business type the bank may consider out of scope, the bank’s written position on that type is confirmed.

Event-driven

Each Tier 3 customer, before activation; each new business type, before the first one

Send the risk memo and diligence package to the sponsor bank, record its written approval or decline, and activate only on approval.

• Risk memo

  Signed memo with the rationale and approval decision

• Sponsor bank pre-approval

  Written approval on file before activation

AML Compliance Officer

Leela can draft the memo from the diligence file and route it to the bank for approval.

Tell Leela about your company to see whether this applies.