Relationship Reviews
Last updated
Last updated
The relationship reviews section contains the onboarding review, all subsequent periodic reviews, and any other reviews that may arise spontaneously (eg: from trigger events) within a relationship. All historical reviews can be browsed, allowing you to view the relationship as it was at the time of the review. This ensures a full account of the decision making process.
This means reviews keep records of ID&V, CDD/ECDD and introducer risk assessment(s) of the customer entity and its controlling party entities as at the time of a particular customer risk assessment and subsequent relationship approval. This encapsulates all the data the customer risk assessment was based on at the time it was completed, and helps keep evidence of the considerations that went into it.
"A relevant person must keep –
(a) a copy of the documents obtained or produced under Parts 3 to 6, paragraphs 37 and 39, including identification information, account files, business correspondence records and the results of any analysis undertaken (or information that enables a copy of such documents to be obtained);"
The Code 2019 33 Record keeping
Relationship reviews also address the specific requirement from the regulator's guidance for the review of the customer risk assessment.
"A documented customer risk assessment is required for every customer, regardless of when the business relationship was established. Similarly, the regular reviews of CRA required by the Code also need to be recorded. "
The Handbook 2023 Section 2.2.9
The relationship review consists of a checklist encompassing the following sections:
Relationship Details: A form containing details about the relationship eg: Nature and Purpose etc...
Customer's Controlling Parties: The controlling parties of the customer entity can can be updated and/or reviewed here directly.
Introducers: The entity representing the introducer of the relationship can be updated and/or reviewed here directly.
Customer Risk Assessment: A form where the customer risk assessment is completed.
Relationship Approval: A form where members with the appropriate grant can approve relationships and select the final risk classification for the relationship.
The checklist is split into several stages. Depending on what stage the checklist is at, the review will have these different statuses:
Profiling
A new review has been started. The team is collecting data about the relationship, its customer, controlling parties and performing the Customer Risk Assessment.
Remediation
The review was sent back by a senior team member at the approval stage. A list of additional tasks for changes to the profiling section is supplied.
Approval
The review is awaiting approval by senior team member(s). They can optionally send the review back with a list of remediations to be made.
Completed
The review has been approved by senior team members.
