Client Compliance Status card
In brief: How to read the file-completeness card on each client profile.
The verdict in the header and the To do list on Overview tell you whether you can act and what remains to be done.
How it differs from the dashboard card
- Compliance Health (dashboard): Are we compliant? For senior partners.
- MLRO Queue (sidebar): What do I action today? For the MLRO.
- Client Compliance Status (this card): Is this file complete? For staff on the case.
Same scoring shape, different scope. Together they're the compliance trinity.
The 10 factors
| Factor | Weight | Cites |
|---|---|---|
| Identity verified | 15 | MLR reg 28(2)(a) |
| AML screening completed | 15 | MLR reg 28(2)(b) |
| AML hits dispositioned | 10 (or N/A if no checks) | AMLGAS ch.5 + POCA s.330 |
| Risk assessment scored | 15 | MLR reg 28(2)(c) |
| Risk assessment current | 10 (or N/A if no score) | MLR reg 28(11) |
| EDD narrative recorded | 10 (or N/A if not HIGH) | MLR reg 33 / 35 |
| Source of funds declared | 10 (or N/A if not HIGH) | MLR reg 35(5)(b) |
| No open material-change flag | 10 | MLR reg 28(11)(b) |
| Beneficial owners recorded | 15 (or N/A for individuals) | MLR reg 28(4) |
| Country risk acknowledged | 5 | MLR reg 33(1)(b) |
"Country risk acknowledged" asks for an EDD record only when the client's country of residence (or, for a company, of incorporation) is a FATF call-for-action country or under UK financial sanctions. A FATF grey-list country is weighed in the risk assessment instead, under geographical risk, and does not need an EDD record on its own.
Russia is on the list as a country under UK financial sanctions. For Russia, EDD is not the whole answer: UK sanctions prohibit accounting, auditing and business and management consulting services to a person connected with Russia (living or located there, or a company incorporated there) unless an exception or licence applies. Check that you can act at all before you start. Russian nationality on its own does not make someone connected with Russia.
How N/A factors work
Factors that do not apply are omitted from To do. Only applicable open items are counted. Completed applicable factors are folded under N done.
This means an individual client without EDD-applicable risk can hit 100% without ever needing EDD or SoF, by design.
Complete the next step
Read the detail beside each item, then choose Open to reach the work. Most factors have a single obvious action:
- Identity not checked yet (individuals) → Complete the identity check
- Companies House record (companies) → Confirm the Companies House record
- No AML screening on file yet → Run AML screening
- High-risk client without an EDD record → Record enhanced due diligence on the Risk assessment tab
- No source of funds declaration → Record source of funds
- No beneficial owners recorded (companies) → Record beneficial owners
- No one acting for the company has been checked → Verify the person acting for the company
The black button at the top of the profile is always the first of these.
How auditors use it
Auditors love this card because it's a direct map from the regulator's requirements to what's done on this specific file. Pull up any client during an inspection visit and you can answer "is this file complete?" in 5 seconds.
Open the risk assessment
Choose Open the risk assessment in Outcome on Overview, or the risk item in To do, to open the Risk assessment tab. Older links to the questionnaire still open it. Companies have a People tab for owners and officers; individuals have a Companies tab for linked companies.
Certivus suggests answers it can back with evidence, and shows the evidence beside each one:
- Identity: whether an identity document was collected, verified and stored, and whether the client passed identity checks (from the identity check or a paper identity check).
- Screening: PEP, sanctions and adverse media (from the AML screening).
- Where the client lives: whether they live in the UK or a lower-risk country, and whether any country is on a high-risk list.
- Communication: "Remote" when the only identity check was done remotely. Change it if you have met the client.
- Companies House (companies): whether the company is on the register, whether its accounts or confirmation statement are overdue, whether it is dormant, and whether its officers changed often. These come from the newest saved Companies House record, which Certivus keeps up to date.
Where the checks support unanswered questions, Accept all N fills those answers together. It never replaces anything you have answered, and it leaves the overall risk, EDD and SDD questions for your own judgement. You can still use Use this beside a single suggestion. Check the answers before choosing Save & Score.
Yes and No start unselected. Choose either, or choose the selected answer again to clear it. If required answers are missing when you choose Save & Score, their sections open and Answer this shows what to finish. Optional questions do not block scoring.
The next step on a client file
The header says whether the client is cleared to act and counts unfinished steps. Select that verdict to open To do on Overview. Its primary button opens the first outstanding step, using the same order as the list. Completed items are folded under N done. When nothing is outstanding, authorised users see Record decision. An approved file still shows any outstanding work.
Overview reads from top to bottom: To do, Evidence, Outcome, Details. Evidence uses full-width rows. Select Report to open the full identity, company or AML report. Individuals have identity and proof of address rows. Companies have a Companies House row, owners and control, and the person acting for the company; People opens their register. Company screening shows sanctions and adverse media; PEP checks apply to the owners. Other-list hits and screening false positives remain visible.
Outcome holds the risk band, decision, next review date and monitoring state. Source of funds and reliance follow it once risk is scored. Details has one Edit and Save for the whole record.
More actions → Run all checks lists identity checks (when needed), AML screening and annual monitoring with your firm's prices and a total before confirmation. Identity options have their own prices; the total starts at the cheapest available option, and you choose and confirm the identity check next. Checks covered by your plan say Included in your plan. You cannot confirm if a price could not load. If saved workflows are enabled, choose Choose a saved workflow instead.
The menu also shows prices for AML check and Verify or Re-verify. Report to MLRO is the final item, separated from routine actions.
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