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.

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.

At the following link Suggested KYC Questions 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

Group ID	Description	Interval
1	Flags related to relationships between KYC Questions	These will only be checked on the day following 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 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.
4	Flags answers to KYC question in relation to transactions	These checks compares the KYC answers with the actual deposit or withdrawals that are made.

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

AML Flag ID	Group	Description

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.
3.5	3	A customer has made a deposit that are above X.
3.6	3	A customer has made a deposit and is Politically exposed.
4.1	4	A customer has entered a KYC answer to a KYC question on total sum yearly deposits that is less than the total sum of deposit annually.
4.2	4	A customer has entered a KYC answer to a KYC question on yearly deposit frequency that is less than the total quantity of deposit annually.

Example of custom field on a person that is needed for 4.1 and 4.2:

Key:
KYC_JSON

Value:
{
"KYC_AnnualDeposit": "10000",
"KYC_NumberOfAnnualDeposits": "6"
}

How will the AML Alerts show up?

AML Alerts are by default being created within BFS as Tasks that can be either manually worked at or automatically handled by another application. Alerts could also be generated for E-mail or for example JIRA.

Within BFS the task will show up looking like the following example in the task list.

By clicking on the task we will navigate to the customer and the full details of the alert will be shown.

From here we can click on the action menu and edit the task to assign it to ourselves and update the status to In Progress for example. We can also add attachments to the task which might be needed during the investigation.

This is how the edit screen looks.

How will any errors be reported?

Inevitably there will be errors somewhere along the way, maybe customers have registered and KYC questions has been missed or the data is not correct for any other number of reasons. At the end of each scan a report will be generated containing detailed information about each customer and why an error was generated. This report can be delivered as an attached file for example via e-mail or as a Jira issue.

An example of the file looks like this.

Adding more flags and groups

More flags and groups can easily be added to the AML Manager and we are here to help, please get in touch with us to discuss your needs.

Ignoring legal entities or accounts

Sometimes you would like to ignore legal entities or accounts from being included in the AML scanning. To do this you can simply add a Custom Field to either the legal entity or an account with field name “AmlMonitoringAgent_IgnoreAmlCheck” and the value set to “true”.