WM Market Reports
Tech Traps: Remember It’s Know Your Client, Not Know Your Criminal

Dermot Corrigan is CEO of smartKYC, a firm taking a truly multi-faceted approach to client screening. Here, he explains why wealth managers are missing out by focusing overmuch on “red flags” – when in fact they can make KYC a competitive advantage by ensuring relationship intelligence is fully leveraged throughout the client lifecycle.
With ever-tighter regulation and the need for enhanced due
diligence when onboarding both individuals and entities as
customers of your firm, it is important to remember what the C in
KYC stands for: client, not criminal.
KYC (Know Your Client) screening has become synonymous with
checking for “red flags” on a firm’s clients, with enhanced
scrutiny and stricter regulation coming into effect since the
terrorist attacks of 9/11.
But client knowledge should never be the exclusive preserve of
the compliance function, nor should it be an activity designed
solely to provide reasons not to do business with someone.
Instead, we advocate a holistic approach, whereby technology-led
relationship intelligence is used to good effect at all stages of
the client journey. Overarchingly, we believe KYC is about
identifying the opportunities as well as the potential risks a
relationship represents, and using everything you can know about
a client to increase satisfaction and loyalty, and deepen wallet
share.
Broad business benefits
The business benefits of this approach are wide-ranging, however,
as it lays a foundation for resolving many of the pain points
that currently plague the sector. Faster, frictionless - and more
confident - onboarding is just the start.
Having a single view of the client, from an intelligence
perspective as well as a process perspective, reduces the (very
real) risk of duplicated effort and critical data loss, but more
importantly it enables better client engagement and the provision
of higher quality advice. It will also help your organisation
function better, putting an end to siloed technology investments
and fostering real alignment between compliance and relationship
managers (RMs).
So, what do we mean by “relationship intelligence”, and when
might it be deployed? In essence, we mean serving up precise,
useable information on clients and prospects. This might be with
an eye on risk or opportunity, and could be before, during or
after onboarding. There are compelling use cases at each
stage.
Pre-onboarding
At the prospecting stage, our technology means that RMs are
alerted to specific lead opportunities as defined by the
business. These lead triggers could include a breaking media
reference to a specific type of liquidity event, a material
change at a corporate registry, such as a new director
appointment, or a new share allocation.
A tear sheet is then automatically generated containing
need-to-know information on the target, including their
background, assets, career history, lifestyle, hobbies,
philanthropic and political interests, source of wealth and so
on.
Furthermore, it might be found that Target A is a patron of
the same charity as happy Client B and the RM therefore has the
potential for a warm introduction to Target A. Armed with all of
this, the RM has a huge head start on rivals, is better informed
and stands a much greater chance of success in signing up that
potential client.
What’s more, we ensure that no effort is wasted in wooing
unsuitable prospects. At this point, preliminary compliance
checks are performed automatically to ensure that there should be
no obvious reason for compliance to reject this client at the
onboarding stage.
At onboarding
This is where full due diligence is completed, but not in the
traditional, labour-intensive and time-consuming way. Instead,
the process is automated so that all external and internal
watchlist sources are screened with a high degree of identity
precision and all elements of exposure risk are addressed,
including to Politically Exposed Persons or sensitive
countries/industries.
Our solution will automatically identify directorships and
shareholding (including ultimate beneficial ownership), check
legal judgment records and corroborate sources of wealth, so that
all the major compliance boxes are ticked.
In addition, we leverage artificial intelligence to ensure
adverse media analysis is carried out with greater precision and
subtlety than ever before. Not only is risk classified in a
fine-grained way (fraud, money-laundering, organised crime, ESG
etc.), but nuances are picked out, such as the gravity of an
offence (e.g. a parking offence versus bribery), or type of
accusation (infidelity versus war crimes).
While this research heavy lifting is done by machine and
presented to the compliance user in the desired fashion (e.g. via
their Client Lifecycle Management system, the smartKYC user
interface or in the form of a dossier), the rules by which the
risk assessment is done are customised by the client organisation
to accord with their risk policies. Decisions are not made on a
binary basis, but rather on a risk-based one.
It is easy to see the business benefits of looking for positive
developments, like a company’s international expansion, which
might represent an opportunity to generate further business from
the client.
Monitoring
If the potential client has indeed been taken on successfully,
our software can then be set to monitoring mode.
Monitoring can be periodic, whereby a full refresh of the client
file is carried out at intervals determined by risk policy. If,
for instance, it has been determined at onboarding that a client
has a footprint in a high-risk jurisdiction and operates in a
high-risk sector, monitoring might be more frequent than would
otherwise be the case.
However, the industry is now trending towards a more proactive
approach whereby all clients are monitored in real time, so that
the business can respond quickly to new developments. If a client
is disqualified as a director, has new charges brought against
them or is cited as a sanctioned individual, a rapid response may
be key to a regulatory defence. Ignorance will of course be no
defence at all.
Yet again though, this should not be all about risk. It is easy
to see the business benefits of looking for positive
developments, like a company’s international expansion, which
might represent an opportunity to generate further business from
the client. At the very least, having a nice reason to pick up
the phone, like a marriage or positive press, can do wonders for
relationships.
Recasting KYC
In today’s data economy, there are incalculable riches of
relationship intelligence available to be harvested. But that of
course means that this wealth of information can become a trap in
itself.
The hard part in any monitoring programme is to ensure that the
business is not swamped either with false positives or by seeing
the same piece of information repeatedly, especially given the
repetitious nature of news. A multilingual semantic search
platform like ours can filter out that noise and so minimise the
risk of seeing the same risk or opportunity multiple times.
Being able to harmonise all your KYC sources and run concurrent
searches on all your clients daily can give you a truly holistic
view of all their respective potential risks and, most
importantly, their needs and requirements.
It is easy to fall into the trap of always thinking about KYC in
the negative or believing that sifting all the thousands of
potential information sources out there is an unwinnable battle.
We believe it’s time for KYC to be recast in a far more positive,
proactive light.
This forms part of this publication’s latest research report,
Technology Traps Wealth Managers Must Avoid. Download
your free copy by completing the form below.