AML Matter Module Overview
The LegalOffice AML module has been developed to complement a firms existing AML programme.
There are many advantages gained by using the LegalOffice AML module. These programs allow you to create a digital record of the due diligence process completed and then, going forward, manage each matter individually so that an audit record of compliance is retained. Transaction activity can be restricted or limited depending on a matters AML status.
AML Matter Module Process
Starting a new matter will involve the following steps;
Completing a Matter Risk Assessment
The Matter Risk assessment (MRA) can be completed from the matter maintenance program during matter creation or, from matter inquiry if the matter has already been created and requires changes be made.
Completing MRA from Matter Maintenance
Open the matter using the matter maintenance program. Use the right click context menu and select ‘Risk Assessment’ or, simply click on the Risk Level icon
The following MRA screen will display.
Answer Y, N or leave the field blank if you do not know the answer. You can return later to complete the form and make changes if necessary. Your answers and workings will be recorded and available for future reference. An audit log will record the username and date the MRA was completed, changed and CO approved.
Your responses to the questions should ‘show your workings’ of how you decided upon the overall rating. Use the ‘Are there any other factors’ field to record your workings.
There are four levels of Risk – Unspecified, Exempt, Standard and High;
- Unspecified means you have not answered one or more questions.
- Exempt means all work on this matter are considered to be a ‘Non Captured Activity’
- Standard means the assessment indicates this is a standard risk matter.
- High means the assessment indicates this is a high risk matter.
The MRA assessment will suggest an overall risk level and you cannot change this. The matter risk level will be set with this value unless you override it using the matter maintenance program. If you do override a matters risk level, make sure you record why you are overriding the recommended setting in the ‘Are there any other factors’ field.
Click OK to save the assessment.
You will be returned to matter maintenance to continue your matter maintenance process. You can now override the suggested risk level if required.
Note that you must click the Save button before you exit matter maintenance as this saves and creates the MRA record.
The assessment is now set as having been completed. The matter is now available in the AML manager program ready for Compliance officer approval.
Complete MRA from Matter Inquiry
To review or amend a matter MRA, open Matter Inquiry for the specified matter and go to the ‘Additional’ tab. On display is the matter risk level and whether or not the matter has been Compliance Office approved.
To change or review the MRA, use the right click menu option ‘Matter Risk Assessment’ to open the RA information screen.
The MRA program will display and function in the same manner as if you had opened it from matter maintenance.
Authorise MRA from Matter Inquiry
Your internal AML programme may require that a Partner authorises any completed MRA. If this is the case, the authorising Partner should;
- Open the matter inquiry program for the appropriate matter ans switch to the Additional tab.
- Note the matter risk level
- Open the risk assessment using the right click context menu and select ‘Risk Assessment’.
- Review the assessment and confirm the suggested risk level is correct.
When satisfied the assessment is in order, you can authorise the assessment using the right click context menu and selecting ‘Approved by Me’.
The assessment is now set as having been approved. The matter is now be available in the AML manager program ready for Compliance officer approval.
Exempt Matters
The AML legislation applies to work defined as being a ‘captured activity’. Where the matter activity is not a ‘captured activity’, the firm can decide to not complete due diligence. In these cases, the EXEMPT status can be used in LegalOffice to record this decision and any relevant explanation.
The EXEMPT process is to set the matter risk assessment level to EXEMPT and for the firms Compliance Officer to approve the matter.
Exempt a Matter from Due Diligence using Matter Maintenance
Open the matter maintenance program and create your matter record.
Set the Matter Risk Level to EXEMPT using the drop down menu option shown on the Risk Level field.
If you wish you can add an explanation of why the matter is Exempt in the MRA ‘Are there any other factors’ field. You do not need to complete the other questions in the MRA. Any explanation you enter will be included on the system generated Exemption Form. Click OK to save the assessment.
Note that you must click the Save button before you exit matter maintenance as this saves and creates the Matter Risk Assessment record.
The matter is now available in the AML manager program ready for Compliance officer approval.