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Effective compliance requires ongoing client monitoring. Applying a risk based approach, the level of monitoring will be calibrated to each client: high risk clients requiring more resources and proactive monitoring. The area of risk will also be different depending on the type of financial institution, business or professional; banks and depository institutions, will be concerned to effectively map financial flows in and out of the account, whereas trust and company service providers (TCSPs) may concentrate on changes to the client ownership and control structure and related transactions.

The Centenal CCM platform is able to integrate transaction and sanction monitoring APIs, as well as provide client structure and beneficial ownership risk monitoring.

Case Study

Below illustrates changes to the Falcon Trust structure, showing investments in Apex Fund Managers, Global Partners and the addition of James Taylor as a beneficiary of the Trust.

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Below illustrates the CCM lifecycle monitor function, graphically recording the entire history of the Falcon Trust for, audit, risk and administrative purposes.

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The “Timeline” scroll confirms investment by BVI InvCo in Apex Fund Management, 1st April 2020.

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The scroll bar then shows investment by BVI InvCo into Global Partners, 1st May 2020.

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Finally, the scroll bar shows the last change entry, the addition of James Taylor as a beneficiary of the Falcon Trust, 10th December 2020.

Different teams including administration, operations, relationship management and investment, may be granted access to the CCM platform to update a change in circumstance or API links may provide a level of automation. The compliance team or relevant screening API will be able to assess the change or proposed change to determine the level of compliance risk. The platform can also alert the compliance team of relevant regulatory reporting requirements, such as in the case where James Taylor is added as a controlling person of the Falcon Trust: this may trigger relevant beneficial ownership reporting obligations.

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