Why this guide?

Institute of Chartered Bookkeepers (ICB) members are supported by the ICB with an AML portal where they need to:

• Complete client risk assessments for each client
• Upload additional AML information, including a firm wide risk assessment

This guide aims to provide ICB members with information on how they can use the Xama platform in conjunction with the ICB portal without duplicating work.

We believe that the two systems can work well together to enhance and streamline the overall AML process.

Using the correct client risk assessment template

As you are required to complete client risk assessments within the ICB portal, you should consider using an abbreviated risk assessment template within Xama.

We have prepared a template for this purpose which is now available in our template library. You can access the library from the risk assessment template manager page within your Xama account here. The template to use in conjunction with this guide is named “ICB – abbreviated client risk assessment”.

This template has been designed such that:

• You do not replicate any of the KYC and risk assessment questions which you are already populating within the ICB portal.
• You can keep track of when a risk assessment has been completed, which means you can use reporting in Xama to help you remember to complete a risk assessment renewal within the ICB portal.
• You can use the template to record the overall risk, but also risk within each section of Client, Transactional, Services, Geographical and Delivery Channel risk. By collecting this information, you can use Xama’s consolidated reporting to more easily complete your firm wide risk assessment.
• You can easily amend the template to include any additional KYC information you would like to record as part of the client onboarding and review process. Those who want to amend the template might find this video on adjusting client risk assessments useful.

The AML process

Using the above template, we suggest that ICB members can set up their AML procedures as follows:

Setting up your clients

Existing clients

AML management software works best if you have all your information organised in one place. This is why we encourage all our users to create all their clients within Xama and organise all the information that you have against those client records. 

You can complete the following steps for existing clients without incurring any costs.

• Create or import your existing clients into Xama. If you have more than a handful of existing clients we would definitely recommend using our import template to do so. You can find the import template within your Xama account here.
• Once you have created your existing clients and related beneficial owners, upload all the AML related documents. When uploading ID documents, ensure that the document expiry date is recorded against the contact record. This will help you manage the process of requesting updated documents in the future. If you take out a Premium trial for 30 days, then you can use the OCR functionality to help you more easily populate the expiry dates for uploaded IDs. Other documents you might want to include are historic AML checks, PEP and sanctions searches and proof of address documents. This is a good opportunity to identify any gaps that might exist within your AML data.
• Record a historic risk assessment against each client. You should use the ICB risk assessment template which we introduced at the start of this guide. 
• By adding all the client risk assessments
  • You will track the overall, client, transactional, services, geographic and delivery channel risk for each client. By tracking this information in Xama, you can use the consolidated reporting to help with producing your firm wide risk assessment more easily. You can access the graphs representing consolidated risk data from within your Xama account here.
  • You can now start using the Xama dashboard which will remind you of any upcoming risk assessments that need to be completed. When a client risk assessment is due, complete this on the ICB portal and create a corresponding client risk assessment in Xama using the custom ICB template. This will ensure that your consolidated risk assessment data for creating a firm wide risk assessment is always up to date within Xama.

Consolidated client risk reporting

New clients

You can use Xama to set up a new client and access all client onboarding features on a pay as you go basis. These include:

• Collecting and verifying identity documents. You can choose to carry out biometric face matching and collect proof of address documents. All documents are securely collected, encrypted and stored within your Xama account.
• You can use the data collected to carry out further AML checks. These include screening against PEP and Sanctions lists, and the verification of an individual’s address against credit bureau and electoral register data.

Once you have completed all due diligence on your new client and have completed the risk assessment within the ICB portal, you can record this within Xama using the ICB template. There is no cost to creating client risk assessments within Xama.

Firm wide risk assessments

If you have followed the above steps, you will have a consolidated set of client risk assessment data. 

Xama provides a sample firm wide risk assessment template which demonstrates how you can use the data from Xama to populate and prepare a firm wide risk assessment.

You can download the sample firm wide risk assessment from within your Xama account.