Purpose
Communicate onboarding, review, delay and restriction matters clearly without promising outcomes or disclosing protected compliance information.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Use approved wording for onboarding requirements | Use approved wording to explain identity verification, screening, risk assessment, documentation, approval and enhanced due-diligence requirements | Approved wording and approval |
| 2 | Avoid implying automatic acceptance | Do not imply automatic acceptance, guaranteed completion times or unconditional access to services | Client communication and delivery record |
| 3 | Request additional information factually | Request additional information factually and only to the extent needed for the applicable review | Information request and rationale |
| 4 | Explain potential delays and restrictions | Explain that activity may be delayed, restricted, refused, blocked or reported where required by law or control procedures | Client communication and delivery record |
| 5 | Protect against tipping-off | Do not reveal or imply suspicious-activity reporting, sanctions review, FIU requests, reporting decisions, internal risk conclusions or investigation methods | Confidentiality and anti-tipping-off assessment |
| 6 | Route sensitive wording to Compliance | Route unusual, sensitive or client-challenged wording to Compliance before release | Compliance or legal escalation |
| 7 | Protect personal information | Protect personal information and send communications through approved secure channels | Client communication and delivery record |
| 8 | Preserve wording and delivery evidence | Preserve the approved wording, delivered message, approval and delivery evidence | Client communication and delivery record |
Onboarding Communication Requirements (Section 6 of the Approved Manual)
Onboarding communication must be transparent, fair, and operationally realistic. Clients should be informed clearly that onboarding is subject to:
- identity verification;
- screening;
- risk assessment;
- supporting documentation requirements;
- approval steps; and
- where applicable, enhanced due diligence.
Onboarding communication must not imply automatic acceptance, guaranteed timelines, or unconditional service access.
Higher-Risk and Incomplete Documentation Scenarios
Where higher-risk characteristics, incomplete documentation, unresolved alerts, or legal restrictions apply, communication should explain the need for further review in a manner that is clear but does not disclose internal compliance conclusions inappropriately or breach anti-tipping-off requirements.
Tipping-Off Prohibition (Section 9 of the Approved Manual)
Any staff communication that inappropriately discloses, confirms, or implies the existence of a sanctions review, unusual activity assessment, or internal reporting process may constitute a serious control breach and must be treated accordingly. Where a communication issue also touches on sanctions, unusual activity review, legal restrictions, or internal compliance handling, the matter must be escalated and assessed in coordination with the relevant control functions.
Exceptions and Escalation
Where ordinary transparency conflicts with legal confidentiality, anti-tipping-off, sanctions, supervisory or security duties, the restricted duty prevails and Compliance determines the permitted response.
Records
- Client communication and delivery record
- Approved wording and approval
- Information request and rationale
- Compliance or legal escalation
- Confidentiality and anti-tipping-off assessment
Relationships
- Policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMM-004 Ensure Onboarding and Restricted Matter Communications Are Safe
History
- 2026-07-26: Created from sections 1, 3 and 5-9 of the approved COMM Manual.