7. CDD Workflow Step: CDD Candidates
1. Navigate to the "CDD Candidates" subsection in the left-hand column. A list of the parties associated with the client will appear here.
2. Next, to the names of the people/entities you would like to include in the entity's CDD, select the AML- relevant relationship.
Relationships that can be selected are:
- Effective control; Authority to act
- Transactions conducted on behalf
- >25% ownership (companies only)
Where the client is an individual subscription, the individual is automatically selected as a CDD Candidate (flagged as ‘Client’) and cannot be removed. Additionally, more than one relationship can be selected per candidate.
NB. If there are candidates missing from the list of CDD candidates, you will have to navigate back to the entities workspace to add in the required individuals.
Be aware that for companies, unless you have manually updated the share register held in Connectworks it will only display the share register as it was recorded with the Companies Office on the day of import. If the share register is up to date and you have identified parties with effective control/beneficial ownership then these individuals will pre-populate as requiring CDD.
If more than one copy of an individual appears in the list return to your Clients>Contacts tab, search for the person and Merge Duplicate Contacts before proceeding with the next step.
3. As you add candidates they will form a list which displays their roles within the entity and the reason for performing CDD.
4. When you are satisfied that the correct people appear in this list, with the correct roles showing beneath their names select the tick box "This section has been completed".
5. Select Update
Note: As you progress through the steps you will notice that ticks begin to accumulate next to each section. This will only occur when it has been marked as complete. If you want to come back to complete a section later simply update in the top right without selecting "This section has been completed". The section will remain un-ticked until updated.
If one of your CDD candidates is another entity (ie. a Company, Trust, Partnership or other) you may wish to also review our article Completing CDD across complicated ownership structures.