AML Data and the AML + Biometric KYC Example Report: Detailed Explanation
A detailed explanation of an 'example' report for a CCH iFirm AML Data Check and a CCH iFirm AML + Biometric KYC checks. This also includes common reasons for failing a check and a breakdown of the check logic used to determine a pass or a fail.
Example Report
Key for results
| Match - Successful match |  |
| No Match – We have searched the record and were unable to find a match |  |
| Not Present – Data is not present on the data source. For example, a data source may not hold date of birth information |  |
| Not Searched – This database has not been searched. This will be because we already have an overall pass from other datasets so we don't have to run the extra checks |  |
Breakdown of our data sources
Before explaining the data sources, it is important to note that we have two different types being positive and negative datasets. A 'positive' dataset means that we are trying to find the individual on the dataset, and the result will be a pass if there is a match. A 'negative' dataset means that we are checking to ensure the individual does not exist on the dataset, and the result will be a pass if there is no match.
- Positive Datasets:
o Electoral Register – A database containing Name, Date of Birth, and Address, of all registered voters in the United Kingdom
o Landline – A database containing Name and Address of Landline users
o National Identity Register – A database containing Name, Date of Birth, and address of those who have opted into the UK National Identity Register. This data is sourced from a growing number of aggregators through marketing campaigns.
o Credit Header – A database containing Name, Date of Birth, and Address, from the three major UK credit bureaus which are Equifax, Experian, and Transunion. These bureaus aggregate data from credit providers such as financial institutions, telcos, and utility providers.
- Negative Datasets:
o Mortality – A database containing Name and Address of all individuals in the UK National Deceased Persons dataset. This check is searching for ‘No Match’ to pass.
o PEP, Sanctions, and Adverse Media – A database containing Name, Year of Birth, and Address any individuals that are politically exposed, sanctioned in any way, or appear in any adverse media scans.
Pass Requirements
For an individual to pass an AML Data check, they must match two positive datasets and two negative datasets, commonly referred to as ‘2+2 Matching’.
Search Logic
When we run a search, we first search the address to see if it exists in the database. If it does, it will return a green tick. After the address, we will then search to see if the name exists in the dataset and is linked to the address. Finally, if the name match is successful then we will search the date of birth to see if it matches the name.
Common Failures
Before explaining the failures, it’s important to highlight the pass rate is 94% which is extremely high for the industry. The failures below are the most common but are clearly still rare given the high pass rate.
- No Positive Match
- Name Mismatch
- Insufficient Data Matches
- PEP Match
No Data Match
It's possible for there to be no match at all on the positive datasets, being Electoral Register, Landline, National Identity Register, and Credit Header. As we search address first, this means that the address does not exist on any of these datasets, and we are unable to continue the search.
This scenario may happen for two reasons:
- It’s a new address that isn’t yet on any database
- There is a typo in the address search
The firm will need to collect an identity document and proof of address if this happens.
Name Mismatch
In this example we have found the address in positive datasets. However, when we have then searched the name, we have been unable to link it to the address.
This scenario may happen for a few reasons:
- The individual doesn’t have any credit in their name and is not on the electoral roll
- The individual has provided an address that they do not have any records at eg provided an old address that they no longer live in
- A ‘known name’ has been searched but the records exist under a legal name eg searched Bob, but the legal name is Robert
- There has been a typo in the name search
The firm will need to collect an identity document and proof of address if this happens.
Insufficient Data Matches
In this example, the individual has matched on one dataset for Name, Date of Birth, and Address. However, they must match on at least two datasets for an overall pass, so this will fail.
Within ‘Credit Header’, it is possible to have two matches because we search across three bureaus. If they match on two, it will be a pass. Therefore, this image can result in a 'pass' or a 'fail'.
The firm will need to collect an additional identity document if this happens.
PEP, Sanctions, and Adverse Media Match
In this scenario, the client was identified as a PEP (Politically Exposed Person) and Sanction match, which always leads to a failed result. When there is a PEP fail it’s important to note this may be a false positive because of the nature of the datasets. We will search First Name, Last Name, and Year of Birth, so it’s possible for it to be someone else on the dataset, not the client. In this scenario it’s up to the firm to do their own investigation beyond this and determine whether or not they wish to proceed.
Other Queries
Aside from ‘why has a check failed’, we have other FAQs which are described below.
Driver Licence/Passport NA
In this verification, it has been confirmed that the client has cleared the AML check. However, the Driver's License indicates 'N/A'. This will always be the result as there is no database to verify UK Driver Licences or Passports. Our AML provider does do some international checks that can verify documents directly with the respective governments, and this is on our roadmap to introduce.
Passport searches will also act in the same manner.
International Clients
We usually have questions about international clients and whether checks can be run on them. Before answering, further questioning is needed on what is implied by international client – it may mean someone living overseas, or someone living in the UK that is not a UK citizen.
The check is all about where they currently reside, rather than where they are a citizen.
- If they have an international document but have a UK address, then you can run a check.
- If they live outside of the UK, then the check cannot be run regardless of the nationality/document.