KYC, AML and sanctions screening answer different questions
Know-your-customer work establishes customer identity and relationship information; anti-money-laundering monitoring examines activity for investigation; sanctions screening tests relevant identities and transactions against specified restrictions. Their findings answer different questions within a financial institution’s control process.
Customer identity and activity monitoring
Know your customer, or KYC, is a workflow label covering identity and relationship information. Customer due diligence, or CDD, includes assessment of customer risk within the applicable framework. The particular obligations depend on the institution, customer and jurisdiction.
Anti-money-laundering monitoring, or AML monitoring, examines activity in context. An activity alert identifies a pattern for review under the selected rules or model. It does not by itself establish that money laundering occurred.
A correctly identified customer can generate an activity alert. Successful identity work supplies information for that investigation; it does not answer whether the activity has an adequate explanation.
Restriction candidates and identity resolution
Sanctions screening applies a different decision purpose. A name match supplies a candidate that must be resolved against the relevant identity, relationship and transaction information. US Office of Foreign Assets Control list downloads supply list data; list availability does not make a name-only comparison a complete sanctions analysis.
Take a verified customer whose name resembles a listed party’s name. Customer verification, the possible match and the decision about a proposed transaction remain separate records. Concluding that the verified customer is the listed party requires a resolved identity relationship, not merely the presence of an alert.
A Legal Entity Identifier, or LEI, identifies a legal entity. It does not verify every beneficial owner or determine the restrictions relevant to every transaction involving that entity.
Shared cases and distinct findings
A shared platform can connect customer records, list versions, transactions, alerts and reviewer decisions. The platform still needs to retain the purpose of each case and the evidence supporting its outcome.
An investigation record can identify which rule or model triggered the alert, which input version was used, what additional information was considered and which action was authorized. A fraud intervention, an AML review and a sanctions decision can share inputs while requiring different outcome labels.
Combining all results into a single clear-or-fail field discards these distinctions. A passed identity check can then be mistaken for an activity clearance, or a possible name match for a finding of prohibited identity.
Scope of compliance tooling
The stable architecture separates information collection, detection, investigation and authorized action. What varies is the applicable obligation, population, rule set and decision authority. Product availability or a completed software workflow does not establish that an institution has satisfied every relevant obligation.
Questions about CDD
Does a sanctions name match prove the customer is sanctioned?
No. A name match is a candidate that requires identity and restriction analysis.
Does an LEI establish beneficial ownership?
No. A legal-entity identifier does not verify every beneficial owner.
Sources and method
- CDD Rule FAQs FinCEN
- Sanctions List Service U.S. Treasury OFAC
- LEI Data: Access & Use Global Legal Entity Identifier Foundation
- Fraud Prevention Solutions Feedzai
Read next
- More automated fraud screening can create more manual work
Better screening rates can still create a larger review queue. Work through how transaction volume and alert rates interact.
- LEI, ISIN, FIGI and MIC: identifying the entity, instrument and venue
LEI, ISIN, FIGI and MIC identify different things. Learn why matching an entity, security or venue does not establish permission.
- Electronic recordkeeping: retention, legal hold and eDiscovery
Keeping records, preserving them under legal hold and retrieving evidence are distinct jobs. Map their storage and workflow requirements.
