REGULATORY REQUIREMENTS REVIEW
BSP circular requirements for AML and KYC reviewed and current.
AMLC reporting obligations understood and mapped to HR and onboarding processes.
Client contractual compliance screening requirements reviewed (for BPOs serving international financial services clients).
DATABASE COVERAGE
Compliance screening covers: OFAC, UN consolidated sanctions list, Interpol notices, EU sanctions registers.
PEP registers included in screening scope for all relevant roles.
Adverse media screening included for high-access and high-risk roles.
Philippine-language media sources included in adverse media screening scope.
Database update frequency confirmed with provider: daily for OFAC and UN lists, near real-time for adverse media.
HIGH-RISK ROLE IDENTIFICATION
All roles with access to customer financial accounts, payment systems, or approval authority identified.
PEP-enhanced due diligence applied to all identified high-risk roles.
Beneficial ownership verification conducted for all vendors and business partners above a defined contract threshold.
CONSENT AND DOCUMENTATION
Candidate consent for compliance screening obtained separately from general employment consent where required.
Compliance screening records include: subject name, databases searched, database version and date, result, and reviewer.
Records formatted for regulatory submission, not just internal review.
ONGOING MONITORING
Periodic re-screening schedule defined for high-access employees.
Process in place for rescreening when a new sanctions or watchlist addition is identified that may affect current staff or partners.
Escalation process documented for positive matches: who is notified, within what timeframe, and what action is taken.
AUDIT READINESS
Complete compliance screening file retrievable within 5 minutes for any current employee in a regulated role.
File contains: consent, screening result, source citations, adjudication decision, and any escalation records.
Compliance screening process reviewed by legal or external compliance advisor at least annually.
