Screening and risk
Name screening
Section titled “Name screening”- Lists: sanctions lists, Thai PEP sources, lists announced by AMLO, and the institution’s own internal blacklist. External lists are loaded by the platform operator, and each load is recorded. The internal blacklist is kept by the institution.
- When: a new customer is screened the moment they enter the book. The whole book is swept the night after a new list is loaded, and at least every 30 days.
- Queue: name pairs scoring at or above the case threshold are released, up to 50 a day, highest score first. Each must be decided within 7 business days of release.
- Decision: the maker confirms or clears each pair with a written reason, and the checker signs. Weak pairs are acknowledged by a checker or approver.
- Effect: a confirmed match feeds the risk assessment, and that customer can never be lowered to Medium. A cleared pair is closed, and the reason stays on record.
Risk scoring
Section titled “Risk scoring”Every customer carries a risk level of Low, Medium or High, computed by a three-tier engine:
- Hard overrides set the level outright, for example a confirmed sanctions match or a self-declared political status.
- Policy gates apply rules the institution sets as policy.
- Weighted factors score the rest of the profile, such as PEP status, country and area, and occupation.
The institution’s high-risk country list follows FATF. A daily check reads the FATF website, and a change takes effect only after the platform operator approves it. Officers may propose a risk adjustment with reasons. It is signed like any other decision, and the history is kept.
EDD Intel
Section titled “EDD Intel”EDD Intel is a tab on the application review page and on the customer file. It gathers significant adverse media from public sources: negative news that relates to the laws the customer is supervised under.
It matches on more than a name. The address (house number and district) is checked against every address the institution holds for that customer: registered, current and work. This keeps namesakes out.
Findings are information that supports the officer’s judgement. They are not a risk factor and they do not change the level by themselves.