11. CDD Workflow: First Review & Second Review
AML Workflow Status: First Review
The First Review step in the workflow provides the opportunity for a client manager, firm manager or Partner to review and approve that the information that has been captured up until this point.
When the entity has been progressed to First Review there should be an internal process at your firm to advise the person responsible for this step to log in and check these clients by following the steps outlined below:
1. In the firm workspace navigate to the Work>AML Compliance>Undergoing CDD tabs.
2. In the left column apply the ‘First review’ filter.
3. Click on the name of any company in the first review stage to automatically open the ‘Review & confirm’ section which displays a summary of all the information.
4. If you are satisfied with the summary then simply select the tick box "I have reviewed and confirmed CDD on this client" and then select Submit confirmation.
NB. If more information is required the reviewing manager can navigate back to the appropriate section of the workflow and add or amend the information, then proceed with the confirmation.
AML Workflow Status: Second Review
The second review is for your AML Compliance Officer to make a final confirmation that the CDD has been completed.
Just like the first review, your firm should have an internal process to advise the AML Compliance Officer when there are entities to be checked.
When making the second review you can also schedule a specific date for re-running CDD on the client. If not updated, the system will default to requiring a CDD check again in 2 years.
Once the second review has been completed, the entity will then moved into the Completed CDD tab (at the top) and the entity's next scheduled review date is displayed next to it.
If for any reason you need to update CDD on a client in the Completed CDD tab you can do this by selecting the tick box by the entity name, then using the "..." drop-down menu select "CDD needs updating", then return to the undergoing CDD tab and update as required.