RIVEROS CORP NETWORK | Apostille de la Haya · Notary Public Center · Compliance Officers · USJurisdiction
RIVEROS CORP NETWORK | Apostille de la Haya · Notary Public Center · Compliance Officers · USJurisdiction
The level that applies when risk factors are present: a new investor, a counterparty in a sensitive jurisdiction, an opaque structure or a list match. Sanctions, politically exposed persons, source of funds and know your employee.
Enhanced due diligence is the level of verification applied when factors are present that raise the risk of money laundering or terrorist financing. On top of standard verification, it adds systematic sanctions list screening, analysis of politically exposed persons and documented proof of the source of funds.
If you are dealing with a new investor, a client who arrives through an unusual channel or an angel investor you know little about, this is the level that applies. Not because anyone is presumed guilty, but because at this point the international standard no longer considers ordinary verification enough.
US companies are subject to minimum anti-money laundering and counter-terrorist financing standards. Those standards require screening clients and vendors against lists that are updated periodically.
It doesn’t replace the basic level; it builds on it. The sanctions, PEP, source of funds and close-associate layers are added on top of the standard file.
Two different questions: where the money for this transaction comes from, and how the wealth behind it was built.
Immediate family members and close associates, because they’re the usual channel for distancing funds from their real owner.
One is enough. There’s no need to wait for them to pile up.
The business relationship is established in a way that doesn’t fit what is normal for the industry or the product.
Especially when verification can’t be done in person and depends entirely on remote documentation.
Legal entities whose real purpose is to hold personal assets, with no business activity of their own.
Restaurants, casinos, delivery services, currency exchange: industries where cash is normal, which makes anything abnormal hard to spot.
Corporate chains with several layers, linked jurisdictions or ownership that gets murky halfway down.
Countries without adequate AML systems, or subject to sanctions and embargoes imposed by international bodies.
Before your company does business with a new client or vendor, or carries out certain international transactions, it’s wise to check that none of the parties appears on the published lists of terrorists, drug traffickers and other criminals.
The main one in the United States is the SDN List (Specially Designated Nationals) administered by OFAC, the Treasury’s Office of Foreign Assets Control. Alongside it are sectoral lists and the lists of international bodies.
Two points that are often overlooked:
The real difficulty isn’t searching: it’s deciding.
Screening lists for names that weren’t originally written in Latin characters, or that have half a dozen possible transliterations, produces a constant stream of matches that turn out to be someone else.
That’s why the work doesn’t end at the match. When a name matches but the identifiers don’t line up (date of birth, nationality, ID document), we document in writing what distinguishes the two people. That reasoned clearance is what unblocks the transaction without leaving your company exposed.
FATF Recommendation 12 defines a PEP as someone who holds or has held a prominent public function. Being a PEP isn’t a crime and doesn’t rule out the relationship: it requires documenting it more thoroughly.
Senior public officials, members of the judiciary, military leaders, executives of state-owned companies and political party leadership, at home and abroad.
Immediate family members and close associates. This is the most common way to put distance between funds and their real owner.
With a PEP, the relevant question isn’t where this payment comes from, but how the wealth behind it was built.
Accepting the proceeds of corruption can amount to money laundering in the United States and, in other countries, a violation of their sanctions rules.
That is why you need solid controls for screening clients, partners and vendors, and ongoing review of detection programs: lists change, positions change, and a PEP’s circle changes with them.
Companies have learned the hard way that an insider can pose the same threat as an outsider. In anti-money laundering, it’s widely accepted that equivalent programs are needed inside the organization.
A Know Your Employee program lets you learn the background of a current or prospective employee as far as it is relevant to the position: identity, work history, degrees and licenses, and public records. Done well, it is also a risk management tool.
Your company should also verify that contractors go through screening procedures equivalent to yours: risk doesn’t care whether someone is on payroll or on an invoice.
A legal limit worth knowing before you order it.
In the United States, when a report about a person is used to make a hiring, promotion or termination decision, it falls under the Fair Credit Reporting Act. That brings its own requirements: the prior written consent of the person being evaluated, and a specific procedure if the decision turns out to be adverse.
We handle KYE as document verification for your compliance program. If you intend to use it as the formal basis for an employment decision, tell us from the start: the nature of the engagement changes and it has to go through the channel the law requires.
If you recognize any of them, it’s time to escalate the case.
The business is pushing to close fast; you know that if something goes wrong, the signature on the file is yours.
A common surname hits half the sanctions list, and no one knows which entry it is or how to clear the rest on sound criteria.
The alert goes off, the relationship freezes, and the next step is missing: what documentation to request and how to keep a record.
The money arrives by a route that explains nothing, and the answer you get is generic: “savings,” “family business.”
Insider risk is discovered late, when the person already has access to systems, accounts or sensitive information.
Lists get updated, public officials change, and so does a counterparty’s ownership structure.
What gets reviewed, in what order and how far it goes. You no longer have to decide on the fly how deep to dig.
Matches are confirmed or cleared using specific identifiers, and the clearance is documented so you can defend it.
What documentation to request, how to establish the source of wealth and how to record the decision your company made.
We separate the two questions and track down the supporting documents for each, flagging where the trail goes cold.
We verify the employee or contractor before they get the keys to systems, accounts or sensitive information.
We propose how often to re-screen based on risk, and which events should trigger an early review.
We identify which risk factor requires enhanced measures and record it: it’s the first thing an auditor will ask for.
We start from the basic-level file. If there isn’t one, we build it first: without a foundation, there’s nothing to enhance.
Sanctions and related lists, with attention to transliterations and the 50% ownership rule.
Current or past status, position, jurisdiction and relevant associates.
Supporting documents for the specific transaction and for the wealth behind it.
Findings, reasoned clearances, disclosed gaps and a re-screening schedule.
Led by Zulma Eliana Bourelly, a Certified Anti-Money Laundering Specialist (CAMS), with a team trained in anti-money laundering.
175 SW 7th Street, Suite 1905, right in the financial district.
A news story is not a conviction. The report makes the difference explicit in every finding.
The entire process is handled through documents and video calls.
It is the level of verification applied when factors are present that raise the risk of money laundering or terrorist financing. On top of standard verification, it adds systematic sanctions list screening, analysis of politically exposed persons and their close associates, and documented proof of the source of funds and source of wealth.
When any of the recognized risk factors appears: unusual circumstances in the relationship, a nonresident counterparty, personal asset-holding vehicles, cash-intensive businesses, complex or opaque ownership structures, or jurisdictions without an adequate AML framework or subject to sanctions. One is enough.
It is the Specially Designated Nationals list administered by the US Treasury’s Office of Foreign Assets Control. It names individuals and entities that persons subject to US jurisdiction are prohibited from dealing with, and it is updated continuously.
It provides that an entity owned 50% or more, directly or indirectly, by one or more designated persons is blocked even if its name doesn’t appear on any list. That is why searching for the counterparty’s name isn’t enough: you have to look at who is behind it.
The first step is to determine whether it’s the same person. Identifiers are compared (date of birth, nationality, ID document, address) and the result is documented whether it confirms or clears the match. That written, reasoned clearance is what lets the transaction go ahead on solid ground.
Being a PEP isn’t a crime and doesn’t prohibit the relationship. What it does require is enhanced measures: establishing the source of wealth, documenting the acceptance decision and subjecting the relationship to closer monitoring.
Source of funds answers where the money for this specific transaction comes from. Source of wealth answers how the person built the wealth that money comes from. In PEP cases, the second question is the relevant one, and it’s the one most often skipped.
Yes. The international standard expressly extends the measures to close associates, because placing a family member or associate in between is the usual way to distance funds from their real owner.
It is the internal counterpart of know your customer: verifying the background, identity, work history and licenses of employees and contractors before giving them access to systems, accounts or sensitive information. An insider threat can have the same effect as an outside one.
If the report will serve as the basis for a hiring, promotion or termination decision, in the United States it falls under the Fair Credit Reporting Act, which requires the prior written consent of the person being evaluated and a specific procedure for adverse decisions. Let us know from the start, because the engagement has to go through that channel.
Screening isn’t a one-time event. Lists are updated continuously and public officials change. The schedule is set according to the risk of each relationship, and immediate re-screening is recommended whenever ownership, jurisdiction or activity changes.
No. We deliver findings, reasoned clearances and disclosed gaps. The decision belongs to your company under its acceptance policy, and the legal assessment of whether there is a duty to report belongs to a licensed attorney or your designated compliance officer.
Tell us which counterparty you’re dealing with and what made you hesitate. We’ll tell you what the enhanced report would cover and what documentation it would need.
or call us at +1 (305) 647-3000 · Monday through Friday
175 SW 7th St, Suite 1905 · Miami, Florida 33130
The standard level that enhanced due diligence builds on.
The general know-your-customer procedure.
Existence, good standing, ownership and litigation of a US company.
A document search for marriages and divorces in public records.
