AML Procedures & Controls
We follow a rigorous Due Diligence System, ensuring a full audit trail of the information provided to us within the initial personal factfinding questionnaire:
- Identification verification
- Risk Assessment
- Customer Due Diligence
Monitoring
There will be a minimum compliance due diligence requirement of information/documentary evidence required in place prior to submission of any application; managed through our CRM systems pre-requisites in place; ensuring that without full due diligence documentation attached to said file, business cannot proceed.
Should an attempt be made, the system will this to our attention for review, via the use of automated system reports issued to management for their compliance review & management of information.
Alongside this, we will monitor submitted application compliance and suitability in house, although have an outsourced compliance company (EQI Consultancy LTD) who will work alongside us in the checking of ongoing client compliance files; ensuring the advice provided is suitable, KYC requirements are met and policies/procedures followed; also ensuring the advice and provided information adheres to the clients requirements/needs/disclosures.
Sanctions
Mortgage Matters LTD make use of Experian’s AML Financial Solutions software, integrated within our CRM which has system pre-requisites avoiding application movement without completion of said checks. This provides with a robust audit trail to evidence and demonstrate our checking of the Financial Sanctions List. This is logged within a data secure system integrated and easily accessible within the CRM, with information regularly screened against future lists, continuously managing this requirement.
PEP / RCA
As noted above, the sanction search provider also screens this information, noted and stored within the CRM.
The system has noted elements to input any additional information as to this area, with automated system reports issued daily to management; reporting any risk in this area that would require immediate review. Any client flagged will immediately require senior level sign off, before any business is carried out; only after Enhanced Due Diligence has been carried out, and the file overlooked by our outsourced compliance team.
Ongoing Training
We have an outsourced training provision in place with Traineasy e-learning solutions, who provide a comprehensive suite of up to date, interactive, annual training in relation to regulatory compliance requirements such as: Money Laundering / Financial Crime / Anti-Bribery & Corruption / Whistleblowing / GDPR / KYC / Consumer Duty / Vulnerable Customers ect; ensuring that all staff remain up to date with legal requirements, knowledge & understanding.
The system allows for all data to be stored and assessed at will, with additional/helpful training that, whilst not a requirement of the FCA for regulatory requirements, offers additional knowledge and understanding within the mortgage/financial sector.
