Onboarding a Compliance Officer

Summary

This article details the process for Governing Bodies to onboard a Compliance Officer. While the process is similar to standard staff onboarding, it includes additional, stricter due diligence checks.

When to Use This

Use this article specifically when the staff member being onboarded holds the role of Compliance Officer.

Key Points

Onboarding a Compliance Officer is restricted to users acting as a Governing Body. If you are a sole practitioner or haven't assigned a Governing Body yet, you'll need to designate someone (like a Director or Partner) with that role first so they can onboard you. Once you are onboarded as the Compliance Officer, you'll then have the authority to onboard other staff members, including Senior Managers and Client-Facing Staff.

Key Requirements

Compliance Officers are subject to stricter due diligence requirements compared to other staff. The following checks are mandatory for this role:

• Bankruptcy Register Search: This search must be conducted specifically for Compliance Officers.
• National Criminal History Check: A full criminal history check is required.

These checks are in addition to the standard Personal Due Diligence (PDD) checks required for all staff. The standard checks for all staff include:

• Verification of Identity
• PEPS, Sanctions and Adverse media

Step-by-Step Instructions

To order the mandatory screening checks

1. From the Staff onboarding dashboard, find the staff member you wish to onboard and click the Onboard button in their row.

2. You will be taken to their individual onboarding page. At the top, you can review their contact details and assigned Roles.

3. If the role was not assigned when Setting up the Compliance Centre, click Assign Roles, tick Compliance officer and then click Confirm.

   Tip: You can have more than one Compliance Officer.

4. To change their roles, click the Edit (pencil) icon and select or deselect the relevant roles and then click Confirm.

5. Ensure the mobile number and email address details are completed.

6. From the Personnel Due Diligence (PDD) section, Verification of identity and PEPS, Sanctions and Adverse media, will be selected by default.

7. Scroll to the bottom of the onboarding page and click Order to start the Personnel Due Diligence checks.

   1. The system will send the VOI request for completion by the staff member.
   2. The PEPs, Sanctions and Adverse media screening will be ordered and results returned.
   3. The status for Verification of identity and PEPs, Sanctions and Adverse media will typically change to IN PROGRESS.

8. For Compliance Officers you must complete the Criminal History Check and Bankruptcy Register Search. You can either click the button to order the checks from InfoTrack or triSearch, or click Upload to provide a document you've already obtained.

Uploading existing VOI or PEPs, Sanctions and Adverse media checks

To upload an existing VOI or PEPs, Sanctions and Adverse media checks:

1. Untick either selection.
2. Click the three vertical dots next to your selection and click Complete Manually.
3. To upload the VOI, either Drop or browse files from your device into the pop up and click Complete. The green Completed status will be displayed. Note: Only PDF, DOC or DOCX files are supported.
4. To upload the PEPs, Sanctions and Adverse media checks answer the two questions about whether your client is a politically exposed person or if they are on the sanctions list. Then either Drop or browse files from your device into the pop up and click Complete. The green Completed status will be displayed. Note: Only PDF, DOC or DOCX files are supported.

To complete the Verification of identity (VOI)

Use these steps to review and submit the Verification of identity task after the staff member has submitted their documents. Completing the VOI includes a one-time mobile security code (multi-factor authentication), reviewing the identity information and documents provided (including information automatically extracted from the documents), resolving any issues (and/or manually entering a document when prompted), and completing the final declaration with a digital signature.

1. From the staff member's Personnel Due Diligence (PDD) page, find the Verification of identity task and click Review.

2. You will be prompted to verify your mobile number. Click Send Code, enter the security code you receive, and click Continue.

3. The system will analyse the identity documents. Once complete, you will land on the Verify Identity Information page.

4. Carefully review the individual's details, real-time photograph, and all extracted document information.

5. If any document has a 'Data Match failed' status, you will need to resolve any errors before you can continue.

6. Once all documents are successfully verified, scroll to the bottom and click Continue.

7. On the final page, read the declaration and tick the two confirmation boxes to confirm you have taken reasonable steps and agree to the terms.

   Use your mouse or stylus to provide a digital signature in the signature box.

8. Click Submit VOI to complete the verification process.

9. When the confirmation screen shows VOI completed, either Download report or click Go to dashboard to return to the Staff onboarding dashboard.

To review PEPs, Sanctions and Adverse Media results

Use these steps to review system-generated potential matches for the staff member you are onboarding.

1. After the VOI has been completed and screening results are available, go to the staff member’s Personnel Due Diligence (PDD) checklist.

2. Find the PEPs, Sanctions and Adverse media item and click Review.

3. A screen will appear displaying a list of potential profiles found by the system. The table may include details such as:

   1. Name
   2. Risk categories
   3. Date of birth
   4. Gender
   5. Country
   6. Confidence score Tip: You can hover over Risk categories to see what each category means (for example, Special Interest Individual).

4. If you want to review one or more profiles in more detail:

   1. Select the profile(s) you want to investigate (up to 10) and click Continue.
   2. The status may change to Profiles Requested. Click Review again to open the detailed profile(s). Note: In some cases you may be taken directly to a single profile review page if only one result is returned.

5. On the profile review page, examine the available information, including (where shown):

   1. Profile details (personal information, risk categories, relationships)
   2. Adverse media
   3. Profile notes
   4. Sources

6. To review more context for a match, click View source (where available) to open the underlying source information.

7. Use the dropdown at the top of the profile (usually starting as To review) to classify the profile:

   1. Is a match (the profile relates to the staff member), or
   2. Not a match (the profile does not relate to the staff member). Tip: If multiple profiles were returned, repeat this for each requested profile. The overall screening status will only complete once each requested profile is resolved.

8. After you make a selection:

   1. repeat the review and classification process for each profile you selected (you can switch between profiles using the profile selector dropdown where available), then
   2. click Back to return to the staff member’s onboarding page. The PEPs, Sanctions and Adverse media status will update to reflect your selection (for example, Not a match).

9. If you conclude that none of the listed profiles match the staff member, click No matches at the bottom of the list. Important: Use No matches only when you have confirmed there are no true matches. If you are selecting No matches, do not select any of the profiles in the list.

10. When all profiles have been reviewed and marked (or you have selected No matches), you will be returned to the PDD checklist and the status for this item will update to COMPLETED.

Other documentation

On the staff member’s Personnel Due Diligence (PDD) page, you will see a list of tasks such as Conveyancing or settlement agent license, Suitability checklist, Criminal History Check, Bankruptcy register search, Statutory declaration and Additional Document.

1. Complete the Suitability Checklist by clicking the Complete button next to it.

   1. A pop-up window will appear with checklist items. Review each item and check the boxes to confirm the staff member's suitability (for example, that they are reliable, honest and act with integrity, and that they have relevant skills and competencies). Then click Complete.
   2. The Suitability checklist will be marked as COMPLETED.

2. Complete any optional tasks such as:

   1. uploading a Conveyancing or settlement agent license by selecting the option next to the task and uploading the required files in the popup window;
   2. ordering or uploading a pre obtained Criminal history check;
   3. ordering or uploading a pre obtained Bankruptcy register search;
   4. uploading a Statutory Declaration; or
   5. uploading any Additional Document you may wish to retain.

Onboarding completed

1. Once all mandatory checks show a Completed status with a green tick, click the Onboard button.

2. A blue Notify AUSTRAC box will appear. Once you have submitted the Compliance Officer details directly to AUSTRAC, return to this screen to enter the Date AUSTRAC notified and Name of person submitting notification details and then click Complete.

3. A green AUSTRAC has been notified message will be displayed.

   

4. The Onboarded status of the Compliance Officer will be updated to Completed on the Staff Onboarding dashboard.