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 on whether the security product booked in USA is sold or recommended by a US-registered broker-dealer or its associated person. Such question is displayed when a Security product is booked in USA – see section ‘Triggers’.
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 FINRA 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 FINRA item in the GKYC sub-case of the customer will determine whether the FINRA questionnaire will be displayed.