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What is a programme in KYCP?

April 27, 2021

A programme in KYCP consists of a number of applications that are governed by the same policy or due diligence process. The configuration of a programme in KYCP allows you to define and maintain the entire process of such applications. This includes anything from the definition of key principles (such as Director Natural Person, UBO, Company, etc.), the fields for each of these key principles, checklists, the risk matrix for such fields and entities, document requirements, questionnaires, rules and also the statuses of the lifecycle that such applications will go through.

How to setup programmes for user access
 
Programmes also govern the level of access that your users and teams can access and also you are in control in deciding whether a subject (key principle) can share data across such programmes or not (to achieve the concept of the single customer view). In fact based on the above, here are the options that you can set.
 
1) A programme is to be completely siloed
This means that any subject data in this programme will be completely separate (logically) from all the other programmes. Example, if you are adding an individual called TOM in this programme, and this same TOM happens to be in some other programme, for KYCP this would be a completely separate TOM.
 
2) A programme can share data on subjects with other programmes
If this is the case you would need to identify / bear in mind the following:
 
a. You can decide which programmes are to share data with which other programmes
b. If this is enabled (and referring to the example above) – if TOM is going to be added in PROGRAMME B as a new subject, and TOM already exists as a subject in PROGAMME A, the compliance team of PROGRAMME B would be able to add TOM by using the USE FROM EXISTING feature.
c. When the above happens you can decide which fields of TOM are to be share between PROGRAMME A and B. You can decide that (for example) fields NAME, SURNAME and COUNTRY are to be shared but the rest of the fields aren’t.
d. Same thing with the Document Types. You can decide that the document types proof of ID, proof of address and certificate of incorporation are to be shared but the shareholders certificate of TOM in Programme A is not shared and only stays in Programme A.
e. When you use the feature of (b) above (use from existing) this would also mean that the screening of subjects for PEPs, Sanctions and Adverse Media will be linked to the single customer view of TOM. So its one check but updating all the places were TOM is involved in.
 
Apart for the above you would also need to note the user access of your compliance teams to the different programmes.
 
- You can set users to have access to one or multiple programmes (example the compliance team of the Irish office are to only view and have access to applications in the programme of Ireland).
- If you want the above to be set for user access but still allow for the feature of 2(b) above (the use from existing) you do not need to give users access to the other programmes. So for example, if users in the Irish office of Programme A (Ireland Programme) want to add subject TOM that is in Programme B (UK Programme) you do not have to allow the Irish user to have access to the full programme of UK. Instead KYCP allows you to set the Irish users in a way whereby the Irish user has the right to purely search for a subject to see if they exist in the other programmes without seeing or having access to the application of TOM in the UK Programme.
 
KYC Portal CLM - GRC automation 
 
How many programmes do I need?
 
The number of programmes that you would need to setup in KYCP can vary based on a number of aspects. We help each client decide this based on the approach that they need to take however here are a number of aspects that need to be factored in such a decision:
 
1) Regional differences
Many clients of KYCP use the platform across the different regions of their organisation. These would have offices in different regions such as US, Europe and APAC which instantly leads to differences in how the process of due diligence works. This could be in the form of different teams which would lead to a drastic difference in the STATUSES that you create in a programme leading to a different flow per region.
 
2) Difference in risk perception
This is one of the most common reasons why a separate programme might be needed. Jurisdictional requirements often lead to perceiving the risk on certain fields (such as Nationality being Italian) in a different way. The regulator in the EU might perceive this to be LOW risk but the APAC regulator requires this to be MEDIUM. Such risk variations are also a result of internal policy based on the product or service you are offering. Some clients considering Italian nationality being low risk in corporate services but high risk if I am offering Tax consultancy. Such elements would require separate programmes to allow you to tailor the entire solution based on your granular requirements.
 
3) User access
Another factor would be user access. Some clients would have separate compliance teams whereby one team can only see the applications of one region or product and not the others. This instantly leads to the requirement of having a separate programme.
 
Having said all of the above however, we do have some clients whose remit is to streamline the entire process of due diligence across products and services, across regions and all users and teams. In such a case they create one programme that is used for all the requirements.
 
For more info contact us directly on info@kycportal.com or schedule your live demo with us today. 
 
 
Feature
Specifications
Targeted For All industries
Status LIVE
Keywords compliance, due diligence, automation, programmes, key principles
Direct Benefits Description of Programmes within KYC Portal.