Maintain a defensible control framework aligned to your regulatory obligations.
| Control | Category | Status | Priority | Owner | Last Review | Evidence |
|---|---|---|---|---|---|---|
Customer Identification & Verification (CIP/CDD) Before a customer can use the account, prove they are who they say they are using reliable, independent evidence, not just what they typed into the form. | Customer Due Diligence | Not Started | High | Unassigned | Not set | 6 |
Beneficial Ownership Identification & Verification For any company or trust customer, find out who really owns or controls it (the actual humans), and prove it, before letting them transact. | Customer Due Diligence | Not Started | High | Unassigned | Not set | 7 |
Expected Activity Profiling at Onboarding At sign-up, ask and record what normal looks like for this customer (how much, how often, to where) so monitoring can later spot when they behave nothing like that. | Customer Due Diligence | Not Started | Medium | Unassigned | Not set | 5 |
Customer Risk Assessment & Rating Score each new and existing customer for money-laundering risk from clear factors (who they are, what they do, where they are) so the firm spends most effort on the riskiest ones. | Customer Due Diligence | Not Started | High | Unassigned | Not set | 7 |
Source of Funds Verification For a specific large or unusual deposit, establish and evidence where that exact money came from before it is used. | Customer Due Diligence | Not Started | High | Unassigned | Not set | 6 |
Source of Wealth Corroboration (High Risk / PEP) For high-risk and PEP customers, understand and prove how they built their overall wealth (not just one deposit), and make sure that story is plausible and independently corroborated. | Customer Due Diligence | Not Started | High | Unassigned | Not set | 7 |
PEP Identification & Enhanced Due Diligence Spot customers (and their close family and associates) who hold or held prominent public office, then apply extra checks and senior approval because they carry higher corruption risk. | Customer Due Diligence | Not Started | High | Unassigned | Not set | 7 |
Enhanced Due Diligence Programme For the highest-risk customers, run a deeper, joined-up due diligence package (extra evidence, senior sign-off, closer monitoring) and make sure it actually happens before and during the relationship. | Customer Due Diligence | Not Started | High | Unassigned | Not set | 7 |
Cash Deposit Anomaly Monitoring Flags when a customer pays in cash that does not fit their declared business or income, so unexplained cash can be reviewed before it disappears into the system. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 6 |
Activity vs Expected Profile Monitoring Compares what a customer actually does on the account with what they told you they would do at sign-up, and flags when the two no longer match. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 6 |
Structuring & Smurfing Detection Catches people breaking one big payment into lots of smaller ones to stay under reporting or alerting limits, including when several accounts act together. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 6 |
Rapid Movement / Pass-Through Detection Spots money that arrives and leaves almost immediately, where the account is being used as a channel to move funds on rather than to hold or spend them. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 6 |
Money-Mule & Network Detection Finds accounts being used by other people to receive and pass on dirty or stolen money, and links them together when they are part of the same ring. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 6 |
High-Risk Corridor & Geography Monitoring Watches payments to and from higher-risk countries and routes, and flags activity that does not fit the customer or looks designed to disguise where money is really going. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 6 |
Crypto Blockchain Analytics Monitoring Uses blockchain analytics to check where crypto sent or received by a customer has been, and flags links to mixers, illicit services or sanctioned addresses. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 5 |
Transaction-Monitoring Scenario Coverage Assurance Checks that the firm's monitoring rules actually cover the risks the firm faces, so no major money-laundering pattern is left with no rule watching for it. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 7 |
Transaction-Monitoring Threshold Tuning Regularly tests and adjusts monitoring rule settings so the firm catches real risk without drowning analysts in pointless alerts, with evidence for every change. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 7 |
Sanctions List Screening (Customer & Transaction) Checks every customer and payment against official sanctions lists before money moves, so the firm does not deal with a sanctioned person or entity. | Screening | Not Started | High | Unassigned | Not set | 6 |
Sanctions Screening Coverage & Calibration Testing Regularly tests the sanctions screening engine with known good and bad names to prove it actually catches what it should and is not silently letting hits through. | Screening | Not Started | Medium | Unassigned | Not set | 5 |
PEP Screening Flags customers who are senior public officials or their close associates so the firm applies extra checks before and during the relationship. | Screening | Not Started | Medium | Unassigned | Not set | 5 |
Adverse Media Screening Searches news and public sources for negative stories about a customer (fraud, corruption, crime) so the firm spots risk that lists alone miss. | Screening | Not Started | High | Unassigned | Not set | 5 |
Real-Time Payment Screening Checks the names, banks and countries on each payment message against sanctions lists in real time and holds anything that hits before the money leaves. | Screening | Not Started | High | Unassigned | Not set | 5 |
Name-Screening Fuzzy-Match Tuning Adjusts how loosely or tightly the screening engine matches names so it keeps catching real hits while cutting the flood of false alarms. | Screening | Not Started | Medium | Unassigned | Not set | 5 |
Correspondent Banking Due Diligence Before banking another bank, the firm checks that respondent's ownership, controls and customers so it does not unknowingly process crime or sanctions risk on their behalf. | Screening | Not Started | High | Unassigned | Not set | 6 |
Trade-Based Money Laundering Controls Checks trade finance deals for tell-tale signs of laundering, such as over- or under-priced goods, dual-use items and shell counterparties, before the firm finances or pays for them. | Screening | Not Started | High | Unassigned | Not set | 6 |
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This tool produces a control specification for design and discussion. It is not legal advice; validate thresholds, ownership and status against your own risk assessment and the cited sources before implementing. Your register is kept in this browser (not on a server); we only store the contact details you provide when you request an export.