Intake lifecycle
KYC/AML onboarding: the customer decision, with its evidence.
Submit a counterparty and its documents. Agents screen every party, read the register, follow the ownership and rate the risk, then list what is still open. Your officer decides, a second person approves, and the record keeps who decided on which evidence.
- Sanctions and PEPScreening agentPossible PEP match
- Ownership chainEvidence agentOwner two levels up
- Risk ratingClassification agentHigh · EDD
Case prepared; the possible PEP match and the EDD documents are listed for the officer.
How it works
Submit the customer. Screen every party. Review each hit. Approve with a second person. Record the decision.
- 01SubmitCustomerLogistics company · CHPartiesDirectors and ownersDocumentsRegister extract · ownership chart
Submit the customer, its parties and its documents.
- 02PrepareAgents workingScreening agentPossible PEP matchEvidence agentOwner two levels upClassification agentHigh · EDD
Agents screen every party against sanctions and PEP lists, search for adverse media, read the register, follow the ownership and rate the risk.
- 03ReviewHitPEP · possible matchSourceOpenSanctionsOfficerM. Fischer
Hits that plainly do not match are closed with the reason on file. Every other hit waits for the officer, who clears, confirms or escalates it, with a reason.
- 04DecideYour callApproveReturnApproved · EDD via MLROMLRO decision recorded · not the maker
A second person approves. The checker cannot be the maker, and enhanced due diligence goes to the MLRO first.
- 05RecordDecision recordRecordKYC-2026-0412Snapshotsha256:4be1…a07cSourcesEach with its answerExport PDF
The decision is written to the hash-chained audit trail, and the evidence pack is exported.
Companies and the people behind them, screened against the OFAC and EU sanctions lists, with PEP and adverse media checks.
The product
One onboarding case, from documents to decision
A KYC case in cmpliance, from six uploaded documents and an ownership mismatch to the customer's answer, the MLRO's judgment and the evidence pack.
The review
What should a KYC review establish?
Before a customer is accepted, the review has to answer five questions, each with its evidence.
- Whether any party is on a sanctions list or is a politically exposed person.Screening agentQuestion for your officerDone ·SanctionsPEPevery party checked
- Who owns the customer, through the companies in between, and whether the register agrees with what was declared.Evidence agentQuestion for your officerDone ·RegisterDeclaredcompared
- Whether listed owners hold half or more between them, even when the customer is on no list.Evidence agentQuestion for your officerDone ·50% rulebelow half
- How high the risk is, and whether enhanced due diligence applies.Classification agentQuestion for your officerDone ·HighEDDMLRO review
- Who accepted this customer, and on which evidence.Your callM. Fischer
Manual review: open questions for your officer.
cmpliance: answered with evidence, ready for your officer’s decision.
The rules
Three rulebooks, one customer
Sanctions lists name the people and companies you may not deal with: the OFAC list in the US and the EU's financial sanctions list.
OFAC and the EU financial sanctions list
Ownership rules look past the name: who holds 25% or more, and whether listed owners hold half or more between them.
Your own risk policy decides when enhanced due diligence applies.
The review keeps the three apart and names the one that applies.
The record
A screening hit is not the decision
A hit says a name looks like one on a list. The decision rests on more: the sources that answered and the ones that did not, each hit and why it was cleared or confirmed, the risk rating and the two people behind the approval.
A hit says a name looks like one on a list.
Possible PEP match- The sourcesEach with its answer
- Each hitReason on file
- The risk ratingHigh · EDD
- The two approversOfficer and MLRO
- Only a person confirms a match, and the reason stays on the record.
- Approval takes two people: the checker is never the maker, and enhanced due diligence goes to the MLRO.
- A source that did not answer is never recorded as clear.
Insights
Related reading
KYC onboarding: from documents to decision
Follow a KYC case in cmpliance from six uploaded documents and an ownership mismatch to a customer response, MLRO judgment and the resulting evidence pack.
Read the article
KYC evidence review beyond name screening
How to review KYC evidence for identity, authority, beneficial ownership, expected activity, contradictions, RFIs, EDD, and human sign-off.
Read the article
AI agents for KYC/AML evidence: a buyer's checklist
What to require from an AI agent that prepares KYC/AML onboarding evidence: source-linked facts, stated gaps, screening records, human authority and reconstruction.
Read the article
Common questions
Which lists does cmpliance screen against?
The OFAC SDN list and the EU financial sanctions list, PEP data from OpenSanctions, and a web search for adverse media.
Which registers does it read?
GLEIF and OpenCorporates. The owners declared in the documents are compared with the register.
How far does it follow ownership?
Up to four ownership levels from the customer, across the relationships on file. Every party it reaches is screened.
Does cmpliance approve customers?
No. It prepares the case and stops for a person. Approval needs a second person, and enhanced due diligence cases go to the MLRO.
What happens when a source does not answer?
The source is recorded as unavailable and the case goes to review. A source that did not answer is never recorded as clear.
What does enhanced due diligence check?
That source-of-funds and source-of-wealth documents are on file. Judging them stays with your officer and the MLRO.
What does the evidence pack contain?
Once the case is approved or rejected: the case as a PDF with its SHA-256 hash, and a manifest with the hash of the case snapshot and the head of the audit chain, so the pack can be checked against the record.