Purpose
Ensure employees and other personnel in AML-relevant roles are appropriately screened before employment, access or duties begin.
Scope
This procedure applies to employees and, on a risk basis, directors, contractors, consultants, temporary personnel and vendor personnel performing AML-related functions.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Identify proposed role and screening scope | Identify the proposed role, access, authority and financial-crime exposure and determine the proportionate screening scope. | Screening scope record |
| 2 | Verify identity and candidate information | Verify identity and the information supplied by the candidate. | Identity verification |
| 3 | Check qualifications, employment history and references | Check qualifications, employment history and references where relevant to the role. | Qualification and reference check |
| 4 | Conduct sanctions, PEP, adverse-information and criminal-record checks | Conduct lawful and proportionate sanctions, PEP, adverse-information, integrity, conflict and criminal-record checks where applicable. | Screening check results |
| 5 | Assess fitness, propriety and trustworthiness | Assess whether identified matters affect fitness, propriety, trustworthiness, segregation or access. | Fitness assessment |
| 6 | Obtain Compliance or management review | Obtain Compliance or management review for material findings and document acceptance, restriction, remediation or rejection. | Review and decision record |
| 7 | Complete mandatory screening before employment | Do not permit employment commencement, privileged access or AML duties until mandatory screening is complete and approved. | Screening completion record |
| 8 | Protect screening information | Protect screening information under applicable privacy, access and retention requirements. | Privacy protection record |
| 9 | Repeat or refresh screening | Repeat or refresh screening after a material role, access, legal, risk or integrity trigger where appropriate. | Rescreening record |
| 10 | Retain screening records | Retain the screening scope, sources, results, decision, approver and completion date. | Retention record |
| 11 | Apply proportionality | For lower-risk activities or roles, simplified procedures may be used; higher-risk situations trigger enhanced due diligence, additional verification, or management review, consistent with the handbook proportionality principles. Every employee has a role in maintaining proportional compliance by following procedures relevant to their job function and reporting risks or inefficiencies to their manager or Compliance Officer. | Proportionality assessment |
Evidence
- in-scope role and screening checklist
- identity and qualification or reference verification
- sanctions, PEP, adverse-information and integrity results
- finding assessment and approval decision
- completion date and access or start-date evidence
Relationships
- AML policy: POL-AML-001 AML CTF CPF Compliance Manual
- Employee policy: POL-EMP-001 Employee Handbook
- Processes: PRC-FCI-001 Financial Crime and Integrity, PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-EMP-008 Ensure Personnel Screening Is Completed Before Employment
- Manual coverage: section 1.3 and the employee-screening element of section 10.3.
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Design status: implemented from approved AML/CTF/CPF Compliance Manual version 2.2
History
- 2026-07-26: Created after a full AML manual rescreen to implement the pre-employment screening requirement.