Implementation approaches we have seen include the following:
- The ‘Add products’ screen gets enhanced to cater for extra due diligence data
only for those products which require further information and not for those
where the N&P can be considered self-evident.
Such extra product related data then pre-populates the relevant items in the ‘Product/Service and Transaction risk’. The pre-populated data will be either read-only or amendable by the KYC Analyst.Based on the above extra product related data as well as other answers, the N&P field can be properly answered (which some FIs move within the ‘Product/Service and Transaction risk’ or in a dedicated place on the GKYC CDD sub-case).
- The ‘Add products’ screen gets enhanced as in step 1.
However, such product related data is collected only for the purpose to set up the detecting logic in the TM system. Therefore, it does not appear in the GKYC sub-case, but it feeds – better if automatically – the TM system.Later on, should there be an alert raised by the TM system (for example, due to a serious discrepancy between the actual usage of the product and what was initially expected it to be), the alert could lead to opening a review of the customer file, including a possible modification of the product related data, which in turn will refine the detecting logic of the TM system.