A 'referred' result means that the total amount of successful ID and addresses returned by the system is less than required to pass the AML Search. The number of positive checks required is based on the risk profile you select.
It has been referred back to yourselves so your MLRO or nominated officer can look at the case in more detail and decide if there are any issues that need to be followed up, and if you still wish to engage with this client.
An AML Search result will not ever be updated automatically, as it is solely based on the data you entered and the results found at that moment in time. If someone has been referred there may be a number of factors that you can use to influence the likelihood of a Pass result. Firstly, you can obtain additional documentary evidence from the client and indicate on the search that you have seen them (include references for Passport and Driving Licences to get additional checks), or even upload them electronically. Also, you can try to interview people face-to-face rather than by letter or on the phone as the latter increases the requirements for the number of electeonic results.
If someone has been referred, the only way they will then pass later is if their circumstances change for the positive (i.e. they have further electronic id's avaialble) or if you change the criteria used in the search (different profile, extra evidence etc.), and both of these changes will require you to do an additional search. |