Employee Due Diligence
What is an Employee Due Diligence Program?
Any employee who handles a function of AML/CTF compliance, whether that be in an admin role or development each contributes to the risk of a non-compliance event occurring in your business. For this reason, it is essential you screen a prospective employee who, if employed, is in a position to facilitate the commission of a money laundering or financing of terrorism. Rescreen an employee where the employee is transferred or promoted into a position to facilitate the commission of a money laundering or financing of a terrorism offence.
Verify your employees within the bronID portal
For bronID AML Comply and Adviser users, you can access the employee due to diligence and verification tool available useful for simplifying and automating your employee due to diligence procedure including performing a police check.
Establish Procedures to:
- Identify and verify the identity of prospective or existing employees
- Confirm their employment history
- Determine if they are suitable to be employed in a particular position in the business
Taking into account:
- The role, nature, size and complexity of compliance
- Identifying the risk of a position and whether additional screening needs to be done
- Criminal record checks
- Been subject to disciplinary account by a regulator or legal action or matters in a court of law
- Taken advantage of laws relating to bankruptcy
- Lived in high-risk countries
Perform Employee Due Diligence Checks within the bronID portal
An employee due diligence program must also outline a system to manage an employee who fails, without reasonable excuse, to comply with any system control or procedure under the AML/CTF program.
- Disciplinary action (formal warnings/dismissal depending on the seriousness or scale of the breach)
- Mandatory refresher training, see Employee ML/TF Risk Awareness Training