In the ‘Regulatory details’ step within the Enrich stage, the user (who, depending on the financial institution’s Target Operating Model, can be for example the back-office department responsible for performing due diligence on the customer, or the Relationship Manager or a Mid-office employee) must answer the question – when the second scenario applies (see section ‘Triggers’) – on whether in relation to the OTC product booked outside of the USA the customer has a US nexus that requires obtaining a Cross-Border Representation Letter.

The financial institution can configure this field in the ‘Regulatory details’ step according to their procedures.

In its out-of-the-box behaviour, the input entered within the ‘Regulatory details’ step does not pre-populate the relevant DFA item in the Global AML questionnaire of the customer (i.e. GKYC sub-case) within the Due Diligence stage, but that can be easily configured.

The answer “Yes” to the following DFA item in the GKYC sub-case of the customer will determine whether the DFA questionnaire will be displayed.