What is Customer Due Diligence?
Customer Due Diligence or CDD is the process which relevant information about the customer is collected and evaluated for any potential risk for the organisation or money laundering/terrorist financing activities.
The Trust Compliance screen will help you in complying with the Anti-Money Laundering/Countering Financing of Terrorism and Client Due Diligence (CDD) requirements for your Trust.
Navigation
| From the Main Toolbar, go to Trust. | |
| Select the Trust from the list. | |
| Select Compliance |
As you progress through the CDD Process, CAS 360 will keep you posted on sections that are still required to be completed. Completed areas are highlighted in Green whilst incomplete sections are Greyed.
Click Back and Next to navigate through the sections.
You can always save your progress by clicking Save for Later
The option to download the Compliance Report or all relevant documents is also available.
Steps
1. CDD Required
To begin, confirm whether Compliance & Due Diligence is required.
Toggling to the question Compliance & Due Diligence Required? will open further steps.
| Start Date | The date you will be starting the CDD process for the entity |
| Completed Date | The date you completed the CDD process for the entity |
| Compliance Officer |
Begin typing the Compliance Officer name. CAS 360 will begin searching the Global Contact screen for the person. If the Contact has not been previously added to the Global Contact screen, Click |
| Upload Supporting Documents | Upload any supporting documents appropriate for the CDD process for the entity |
will appear.2. Nature of Business Relationship
| Nature of Business Relationship | Select from a range of options the business relationship between you and the entity. If required, click + Add Another Relationship to select multiple relationship options |
3. Source of Funds
Toggling to the question Source of Funds required? will open further steps.
| Free Text | Enter any Free Text relevant to the Source of Funds in the text box. |
| Uploading Support Documents | Upload any supporting documents, either by drag and drop or browsing for files. |
Toggling to the question Source of Wealth required? will open further steps.
| Free Text | Enter any Free Text relevant to the Source of Wealth in the text box. |
| Uploading Support Documents | Upload any supporting documents, either by drag and drop or browsing for files. |
4. Individuals
The individuals section will list all Members and Officers of the entity.
Also, hover your cursor over the information icon . Users will be able to instantly see the individual's:
Name
Address
Date of Birth
Place of Birth
Mobile Number
- Company Number
To edit any of these details, select
| Question: Compliance & Due Diligence Required? | Toggle |
5. Risk Assessment
When completing the AML/CFT Risk Assessment for a client in CAS 360, users will be guided through a range of questions grouped into six risk categories. These questions help you assess the client's overall risk profile and determine the appropriate level of Customer Due Diligence (CDD) required.
Each question can be answered using a toggle , with options to:
Click the paperclip icon
to attach supporting documents, and
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Click the plus (+) icon to add additional notes or comments.
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Know Your Client
Have all related individuals been identified and verified?
Have all documents showing the trust's establishment been identified?
Have financial records from previous accountants been obtained, and are the trust’s tax affairs clear?
Do Companies House records match the information provided by the trust for the trust's registers?
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Client Risk
Is the client politically exposed?
Is the client evasive or reluctant to engage in AML procedures?
Is the client a publicly owned enterprise?
Are the client’s securities listed on a regulated market?
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Geographic Risk
Is the client based within close proximity to your firm?
Is the client based outside of the UK?
Does the client have any association with a jurisdiction sanctioned by HM Treasury (HMT)?
Does the client have any association with geographical areas known to have weak AML and Terrorist Financing controls?
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Service Risk
Will the client be using your client money account?
Are you a logical-sized and well-positioned accounting firm for the client?
Is it clear why the client has chosen to engage your services?
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Industry Risk
Is the client a cash-intensive business?
Does the client deal with high-value goods?
Does the client operate in a business or industry considered high-risk for money laundering?
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Delivery Channel Risk
Have you met the client face-to-face?
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Custom Questions
Each risk category includes an option to + Add Custom Question, allowing you to tailor the assessment to your specific AML/CFT procedures or industry-specific requirements.
Risk Level / CDD Level
| Question: Having reviewed the above risk areas, the overall risk rating for the client is | Rate the entity risk level |
| Level of CDD Required |
Standard customer due diligence This involves identifying the customer, and ensuring it is based on a reliable independent source. The purpose and intended nature of the business relationship or transaction must be assessed and further information obtained where appropriate. Simplified customer due diligence This can be applied when a risk assessment has shown a negligible or low risk of money laundering. The only requirement is to identify the customer and there is no need to verify the customer’s identity. Enhanced customer due diligence Enhanced CDD must be applied when the risk of money laundering is high, such as if the person in question is a politically exposed person. |
6. Notes
Additional findings arising throughout the AML/CDD workflow can be recorded here.
To begin recording additional findings, click
CAS 360 will display the Add Note window.
Each note can have a title and the note content. CAS 360 will also display a time stamp to show when the note was last modified.
Notes can be deleted by selecting beside the note.
Click to add any additional notes.
Click to save note.
7. Risk Review
| Completed By | Select, from a list of your CAS 360 users, the user completing this CDD process |
| Date Completed | Date the CDD process has been completed |
| Next Review Required | Date the next CDD process will be required |
At Step 7 – Risk Review, you have the option to . Clicking this button sends the compliance report to a designated team member using CAS 360’s Document Review feature.
- The reviewer will receive a notification and can either approve or return the document.
- Once approved, the record can be marked as complete.
- Optionally, set the Next Review Required date for future compliance reviews.
This feature is optional but highly recommended for teams with internal compliance workflows or designated compliance officers.
If Compliance & Due Diligence is not required
Leave the 'Compliance & Due Diligence Required?' toggled to no and complete the following fields:
| Next Review Date | Date the next CDD process will be reviewed. |
| Reviewer's note | Enter in the reasoning for why the company/trust does not need to be CDD process to be completed. |
| Upload Supporting Documents | Upload any supporting documents to provide evidence for the reason to not process CDD for the entity. |