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Bricknode AML Manager is an application that can automatically conduct Anti Money Laundering monitoring to keep you compliant.

The application will create Tasks within Bricknode Financial Systems (“BFS”) if there are any AML alerts that needs to be investigated.

A multitude of different checks can be conducted and we can easily add more checks on request to your subscription.

We call each check an “AML Flag”, for example, AML Flag 3.2 defined in the table below will create alerts if a customer has deposited money during the month that is above a certain limit defined by you.

Currently we have the following Flags that can be monitored by default and we split them up into certain groups, currently three.

Info

Below we reference KYC (Know Your Customer) questions that have been stored in BFS. These are commonly stored as custom fields using the KYC_ prefix before the name of the KYC question or stored as a JSON object. Further down in this document we have a suggested naming convention for storing KYC questions and answers, however, within the AML Manager you can define your KYC Question names that you have used.

Group ID

Description

Interval

1

Flags related to relationships between KYC Questions

These will only be checked on the day following the the submission of new or updated KYC Question data, this ensures that they will only be checked once each time the KYC info is updated and not trigger a possible alert every day.

2

Flags answers to KYC questions that breach certain limits

These will only be checked on the day following the the submission of new or updated KYC Question data, this ensures that they will only be checked once each time the KYC info is updated and not trigger a possible alert every day.

3

Transaction monitoring

These will be checked on the first day of the calendar month for the previous calendar month.

Currently you can subscribe to any of the following AML Flags.

AML Flag ID

Group

Description

1.1

1

A customer (Legal entity) that has entered a KYC answer to a KYC question that they will save more each month than their gross income per month.

1.2

1

A customer (Legal entity) that has entered in KYC question an amount for the monthly savings amount where it does not agree with what they have entered that they will invest each time.

Here we are looking at the range stored for capital to invest and reading the upper value and then multiples the monthly savings amount by 12 months to check if this is above the maximum capital to invest level.

1.3

1

A customer (Legal entity) that has entered in KYC question for starting amount that is larger than X % of the entered amount for total assets.

2.1

2

A customer (Legal entity) that has entered in KYC question for monthly savings an amount that is larger than X.

2.2

2

A customer (Legal entity) that has entered in KYC question for starting amount that is larger than X.

3.1

3

A customer (Legal entity) has made total sum of deposits during the month that are above X or 6 x GrossMonthlyIncome, whichever is higher.

3.2

3

A customer (Legal entity) has made total sum of deposits during the month that are above X.

3.3

3

A customer (Legal entity) has made >= X number of withdrawals during the month.

3.4

3

A customer (Legal entity) has made X number of withdrawals per month during the last X number of months.