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AML screening for small, international clients – what's standard practice?
Starting to onboard a few more micro-cap international clients for advisory services, and our current AML screening process feels overly burdensome for the fee size. I'm wondering what other small to medium firms do for clients who barely cross a certain income threshold but are in higher-risk jurisdictions. Is it overkill to run full EDD on every single one, or are there tiered approaches that are compliant but more efficient for lower-revenue clients?
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If you're dealing with higher-risk jurisdictions, you really can't cut corners on EDD, regardless of fee size. The regulatory penalties for getting it wrong far outweigh any perceived efficiency gains from a tiered approach for those specific clients.