Suggested way of working with Trapets InstantWatch KYC

Trapets is a widely used software service for staying compliant with AML regulations. Bricknode Financial Systems (“BFS”) and its verticals have integrations with the services provided by Trapets and this article describes a best practice case for how to work with the interaction in an automated fashion.

A common case is for customers to be scanned against Trapets InstantWatch KYC when they are onboarded to BFS.

Another common case is for daily scans of the complete customer base to occur against IW KYC to make sure that no customers have been placed on sanction lists or PEP-lists.

It is important to be notified about required investigations of customers and in the case of onboarding an investigation probably has to take place before the customer can be approved for business.

Suggested process

In the onboarding applications delivered by Bricknode there is an option to enable Trapets lookups when a new customer signs up, is migrated from another system or new KYC data is collected. If a match is found this information is saved to a custom field called Trapets_Kyc_Record_Json on the customer in BFS which can be found on the Details section of a LegalEntity. And a Task is created in BFS for administrators to investigate the customer.

This format can be easily read by machines via API and can also be parsed and read by humans easy enough. By holding the cursor over the value field and clicking the left mouse button while pressing the ctrl button the full content will be copied. You can then navigate to a service like http://jsonviewer.stack.hu/ where you can paste the content in the Text tab and then get the data organized in the Viewer tab.

We can use this information to see if this in fact is a possible match in BFS. At the bottom of the record where it says “SourceName” we can see in what list the match was found.

How should we act when investigating? See the tree below:

  1. Is the customer a PEP?

    1. No

      1. Create a new custom field named “Trapets_Kyc_Investigated” and set the value to “true”.

    2. Yes

      1. Create a new custom field named “Trapets_Kyc_Investigated” and set the value to “true”.

      2. Check the box “Politically exposed” in the Status section:

         

      3. We need to collect additional questions from the customer which can be done on a physical form and uploaded as a file to the customer in BFS.

  2. Is the customer on a Sanction list?

    1. No

      1. Create a new custom field named “Trapets_Kyc_Investigated” and set the value to “true”.

    2. Yes

      1. Create a new custom field named “Trapets_Kyc_Investigated” and set the value to “true”

      2. Set the customer to “Is Locked Out” in the status section.

      3. Investigate if the customer should be accepted or closed.

  3. When the investigation is done set the Task to Done and make sure that the custom field called “Trapets_Kyc_Investigated” was created with the value set to “true”.

The custom field called Trapets_Kyc_Investigated is created so that daily scans of all customers will know that the match has been investigated already and not to create new investigation tasks each day.