CISI Global Securities Operations study materials
CISI Global Securities Operations study resources

CISI Global Securities Operations: Client Onboarding, KYC and Anti-Money Laundering in Operations

CISI Global Securities Operations · Work through your exam, one topic at a time.

All guide sections

Client Onboarding, KYC and Anti-Money Laundering in Operations

What this domain tests

This domain tests the risk-based approach to customer due diligence, beneficial ownership, screening and monitoring, and the operational controls that keep onboarding defensible under FATF standards and local AML rules.

Customer due diligence

  • CDD: identify the client, verify identity using reliable independent sources, understand the purpose and intended nature of the relationship.
  • Beneficial ownership: identify the natural persons who ultimately own or control the entity, typically at a 25% threshold, and verify them.
  • EDD is required for higher-risk situations: PEPs, high-risk jurisdictions, complex structures, correspondent relationships.
  • Sanctions screening at onboarding and on an ongoing basis against consolidated lists; hits must be investigated and resolved, not simply cleared.

Ongoing obligations

  • Risk-rate the client and set a review cycle; triggers include a change of control, unusual activity, adverse media or a new jurisdiction.
  • Transaction monitoring alerts are investigated and, where suspicion remains, a SAR/STR is filed to the FIU. Tipping off the client is a criminal offence.
  • Records must be kept for five years after the relationship ends under the UK Money Laundering Regulations.
  • FATCA and CRS tax classification is collected at onboarding alongside KYC.

Worked example

A fund incorporated in the BVI applies, with a nominee shareholder and an investment manager in Cyprus. Reasoning: the nominee is not the beneficial owner, so operations must look through the chain to the underlying investors and identify any person holding 25% or more, verifying each with passports and proof of address. The BVI and Cyprus elements plus the nominee structure push the client to high risk, requiring EDD, source-of-wealth evidence, senior management approval and enhanced ongoing monitoring. The fund's LEI and tax classifications are captured in the same onboarding pack.

Traps that cost marks

  • Accepting the nominee or corporate shareholder as the beneficial owner.
  • Treating PEP screening as a one-off onboarding check.
  • Failing to distinguish source of funds from source of wealth.
  • Discussing a SAR with the client, which constitutes tipping off.