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Name screening

CDD Core screens every applicant and every customer against sanctions, Domestic PEPs, AMLO and the institution’s own lists — at once for anyone new, and again whenever a list changes. A maker decides each name pair in writing and a checker signs. A confirmed match feeds the risk level; a cleared pair stays on record with its reason.

Who may do it: Maker (decide pairs) · Checker (sign) · Approver (read; signs Domestic PEP clearance requests and the cut-offs) · Compliance Officer, Head of Compliance and Internal Audit (read).

Name screeningThe name matcher checks customers against sanctions, Domestic PEPs, AMLO and internal lists; pairs above the threshold enter a queue; the maker confirms or clears them in writing, the checker signs, and a confirmed match feeds the risk level.SIGN-OFFCONFIRMEDCLEAREDListssanctions · Domestic PEPsAMLO · internal blacklistCustomer booknew customers at onceName matcherfull sweep after a new listand at least every 30 daysMatch queueup to 50 released a day7 business days to decideMaker decidesconfirm or clearreason in writingChecker signson the sign-off routeRisk levelnever below MediumClosed with reasonreason stays on recordLEGENDRegisterStepAutomatic
From lists to decision. Every adjudication carries a written reason and a second signature.

The lists

Section titled “The lists”
  • AMLO state-authority lists: FREEZE-04 (UN), FREEZE-05 (Thailand) and HR-03 where it is in the institution’s obligations. Loaded by the platform, shown read-only with the issuing authority, list date, load date and record count. No role can edit, add or override them.
  • External sanctions and PEP lists: the provider is a setting, not part of the product; delivered daily by file or in real time.
  • Domestic PEPs: a platform layer (AMLO’s baseline definition, family and close associates) and an institution layer for broader categories the institution defines, imported by its Risk Manager.
  • The institution’s prohibited customer list: applied to new applicants only.
  • DA Dealer: agency mule-tier lists and wallet lists as well.

When a person matches an AMLO list and another list, the AMLO outcome applies.

When screening runs

Section titled “When screening runs”
  • New applicants and customers: at once, on entry.
  • A change of particulars: at once — address, postcode, nationality, occupation or source of income.
  • Every night, between 00:30 and 06:00 Bangkok time: a full sweep of the book after a new list lands; only new and changed customers when no list has landed; nothing when neither happened; and a full sweep at least every 30 days whatever happens. A large book is swept in slices across several nights, and a run is never left half-done.

Sweeps start on the system’s schedule. No role at the institution can start or stop one.

Scoring and release

Section titled “Scoring and release”

Each name pair carries two scores against two lines: the case line opens a case; the lower weak line marks a weak hit. Two names of several words need two matching word pairs; a one-word name is not screened. Pairs at or above the case line are released up to 50 a day, highest score first, so the team gets a day’s work, not a backlog.

The lines are a signed, versioned parameter. An institution may only make them stricter than the platform’s defaults. A change names its resolution, reason, effective date and the Risk Manager who owns the value; the Maker proposes and the Approver signs; one version may wait for signature at a time. A new version applies from its effective date and reopens nothing in the past.

Steps

Section titled “Steps”
  1. Maker opens a pair from the queue or from your work and compares the customer with the listed entry.
  2. Choose Confirm match when it is the same person, or Clear when it is not, with a written reason. The reason becomes part of the register.
  3. Checker signs Approve or returns it. Whoever decided the pair cannot sign it.
  4. Decide each released pair within 7 working days (Monday to Friday).

Weak hits

Section titled “Weak hits”

A weak hit opens no case and changes no risk level. It is a fact placed in front of the signer: at the approval step, the Checker or Approver acknowledges it once (a Maker may not), and an approval is refused while one is outstanding. Weak hits come back for review at Re-KYC, when the risk level rises, and when a list load moves a name across the case line.

Domestic PEP matches by name only

Section titled “Domestic PEP matches by name only”

Pairs matched on Thai first name and surname, against PEP entries with no identity number, have their own screen. The Maker files a clearance request with a reason and a PDF or PNG attachment; it is signed on the institution’s route. An approved clearance stops the pair counting at the next assessment. Pairs matched on identity number are not on this screen and cannot be cleared.

What the system does or refuses

Section titled “What the system does or refuses”
  • A confirmed match feeds the risk level and the customer can never be adjusted down to Medium while it stands.
  • A cleared pair stays quiet on later sweeps until the listing’s names or status change. It is never hidden: it keeps its row with the reason.
  • Overdue pairs are shown as a fact — due date, days past due, sorted first — on the Approver’s and Internal Audit’s views. No level moves and no account closes because a pair is overdue.
Section titled “Related”