AML, Sanctions and Information About Transaction Participants

A one-off review answers questions about a specific counterparty. An AML procedure is needed when directors and responsible employees must assess many customers, suppliers, payment recipients or participants in international transactions consistently and in the same way.

The scope depends on the product, countries, payment methods and the role of your company. For a domestic supply, registration data, ownership, authority and transaction documents will usually be sufficient. In an international transaction, the bank, currency, intermediaries, ultimate consignee, ownership structure and applicable sanctions lists may also be relevant.

UBC specialists agree the criteria before reviews begin. Employees understand which information must always be requested, when enhanced review is required and who makes the final decision on the transaction.

The working procedure may include:

• identification of the company, sole proprietor and signatory;
• review of owners and persons who control decision-making;
• screening participants against applicable sanctions sources;
• confirmation of business activity, payment purpose and the economic substance of the agreement;
• review of a licence or permit where it is required for the stated activity;
• recording the result and the list of documents obtained;
• repeat review when ownership, account details or the payment structure changes.

A different scope can be established for each customer group. This allows enhanced review to focus on transactions where it is genuinely needed while preserving a simple process for ordinary agreements.

AML and sanctions control requires information on the business activity, typical customers, countries, payment methods, current questionnaires and agreements. UBC specialists determine the information and documents needed for the specific transactions and the allocation of responsibility between employees.

For a specific transaction, UBC specialists review participants, owners, authority, sanctions information and payment documents. The forms and evidence list should be suitable for internal use, a bank, auditor or business partner.

For ongoing work, continuous support for complex customers and document updates when requirements change can be agreed.

Payment, Agreement and Supporting Documents

To set up the system, send a description of the business, list of goods and services, main countries, currencies and payment methods, customer types, current agreements and questionnaires. Indicate who currently collects documents and who approves transactions.

For a review of an individual customer, provide its registration data, ownership structure, information about management, the draft agreement, and the purpose and flow of payments. If an intermediary, carrier, agent or another recipient of funds is involved, their data are also included in the assignment.

AML control is useful when the result is linked to a specific payment. The agreement, invoice, payment purpose and bank details should identify the same parties, goods or services, amount and settlement basis. If money is received by an agent, manufacturer or another person, that role should be described in the documents in advance.

UBC specialists assess whether the payment structure corresponds to the agreement and actual performance. For an international transaction, they also compare countries, currency, banks, intermediaries, carrier and ultimate consignee. This comparison helps prepare a package that employees can quickly provide to the bank together with an explanation of the economic substance of the transaction.

The internal procedure should specify what to do when bank details or transaction participants change. A new recipient, another bank, an additional intermediary or a significant change in amount is a reason to return to the documents before payment. The responsible employee records the change, obtains confirmation and refers the matter for enhanced assessment where required by the company's criteria.

For existing customers, an up-to-date questionnaire and transaction history can be used. This reduces repeated collection of the same information and allows attention to focus on changes that genuinely affect the next decision.

A potential match must be resolved by identifying the person before a final conclusion is reached. UBC specialists determine which person the information concerns, compare identifiers and assess the link to the transaction. A namesake, a company with a similar name or a previous address requires separate clarification before the conclusion is recorded. The result of the analysis is documented together with the evidence on which it is based.

If the risk is confirmed, the owner receives options: request additional information, change the settlement procedure, remove an unverified intermediary, establish a condition precedent or decline the transaction. UBC specialists explain the contractual and payment consequences of each option. Management makes the decision and retains a clear record of the reasoning.

For urgent transactions, the persons authorised to approve an exception or stop a payment are identified in advance. A manager can then escalate a difficult matter quickly to the responsible executive with a concise summary and supporting package.

Result for Management and Fee

You receive a clear internal procedure, data-collection forms, criteria for standard and enhanced review, and documents for customers already assessed. The result can be used when approving an agreement, payment, banking relationship and internal control.

The fee depends on the number of customer categories, countries, participants, documents and depth of review. Before work begins, UBC specialists define the composition of the system or specific assignment and agree the price.

Describe your customers, countries, payment methods, average transaction size and current review process. Add questionnaires, agreements and examples of unusual payments. UBC specialists will compare the risks with the company's actual transactions and prepare information lists, standard and enhanced review scopes, an approval procedure and decision forms.

The responsible employee maintains a customer or counterparty file showing information sources, ownership structure, signatory authority, purpose of the relationship and expected transactions. The review must lead to a clear decision: commence work, request clarification, impose restrictions or refer the matter to the responsible executive. The date, author and basis of the decision are retained.

The responsible employee takes sanctions information into account when making payments, supplying goods and changing parties to an agreement. Repeat review is performed on an event-driven or periodic basis, and potential matches and confirmed identification are considered separately. The team receives a procedure for handling unusual transactions and a single evidence-retention process. Employees use that procedure when supporting transactions and make consistent decisions without unnecessary delay.