How to ensure a solid KYC-process in Creditro Comply

When it comes to anti-money laundering processes, one thing is certain: documentation, structure and ongoing oversight are essential. That is precisely why Creditro is designed as a framework tool for creating transparent and well-documented processes – both in day-to-day operations and when the supervisory authority comes knocking.

Many organisations may be tempted by “plug-and-play” system solutions, but a standard setup is no longer sufficient when it comes to AML compliance. You must assess your specific conditions and circumstances and, based on all relevant factors, build the most comprehensive KYC process for your business.

Below are examples of key areas you should focus on to strengthen your KYC process – and how you can tailor these processes within the Creditro Comply platform.

A softwarepartner rather than a standard solution

No two businesses operate with the same risks and processes. Quite simply because industries, customer types and services differ. For that reason, it is essential to build and document a KYC process that fits your business precisely.

A standard configuration or generic approach is rarely sufficient today, and it is crucial that all elements align with the procedures described in your internal policies and procedures in accordance with § 8. In Creditro, you can customise client types, services, questionnaires and risk self-assessments. These are exactly the kinds of customisations that supervisory authorities increasingly expect businesses to be able to document.

Ultimately, it is your responsibility to ensure that the questions being asked are relevant to your customer base and aligned with the processes described in your internal policies and procedures. The importance of tailoring your processes cannot be overstated – regardless of whether you use a system solution such as Creditro or take a more manual approach.

Example: purpose and intended nature of the business relationship

Supervisory authorities are increasingly focusing on two key elements that many businesses still struggle to document clearly: the customer’s purpose and the intended nature of the business relationship.

1. The customer’s purpose

When assessing purpose, you must evaluate why a customer wishes to enter into a business relationship with your firm.

You may, where relevant, assess and ask questions such as:

• Why does the customer require the services you offer?

   

• Does the requested service align with the customer’s stated industry classification and actual business activities?

   

• Why does the customer wish to establish a business relationship with your firm specifically?

   

• Was your firm recommended to the customer? If the customer is located far from your firm geographically, it may be relevant to explore why they chose you.

• Is the purpose of the business relationship long-term, or is the service more short-term in nature?

A business must therefore determine what information is relevant to collect in order to assess the customer’s purpose. This may include, for example, the customer’s articles of association, a company register extract showing the industry code, or similar documentation.

All of this documentation can be managed within Creditro Comply – both in terms of collecting relevant information and ensuring GDPR-compliant storage.

2. The intended nature of the business relationship

When assessing the intended nature of the business relationship, the focus is on building a clear picture of the customer’s business model, source of income and source of funds in relation to the services you provide. This clarifies the character of the relationship and the specific services to be delivered.

The objective is to assess whether the customer’s activities are logical and proportionate from a risk perspective, and whether they are consistent with what the customer wishes to have carried out.

You may, where relevant, assess and ask questions such as:

• What does the customer’s business model look like?
• What income streams does the customer have?
• What is the customer’s overall source of income?
• What is the source of funds for the requested service?
  • For example, for company formation or restructuring.
• What is the source of funds for renovation of a rental property, or for purchase and sale transactions?
• Do these funds align with rental income, available equity in the property, personal wealth, or similar?

Simple documentation with Creditro

Whether you work within your own systems or use a system partner such as Creditro, it is essential to ensure that your setup aligns with the internal procedures described in your § 7 and § 8 documentation.

You can incorporate these questions into your risk self-assessment and/or customer questionnaires. In Creditro, this can be easily integrated so that all documentation is collected in one place and follows a consistent structure.

We have prepared a short walkthrough highlighting the key elements you can adjust in your Creditro Comply configuration. These settings can be updated on an ongoing basis, and we always encourage our customers to continuously refine them as their KYC processes evolve. This is the best way to ensure alignment between documented procedures and practical implementation.

Are your § 7 and § 8 documents up to date?

If your internal policies and procedures need updating, or if you want to ensure full alignment between documentation, practice and your Creditro Comply setup, we can help through Creditro Consultancy.

Through this service, you receive expert advice from a qualified lawyer and assistance in preparing your documentation package, ensuring it reflects both your system setup and your practical workflows. You are always welcome to contact us for a non-binding discussion about Creditro Consultancy.

In our help center you will also find a range of guides, articles and FAQs that can support your daily work with Creditro Comply. Here, you can continuously find answers and inspiration related to both the platform and your compliance processes.