Sampan - KYC Refresh Platform for Periodic and Trigger Reviews

Dashboard, case queue, case review, trigger events inbox and non-response ladder, with 13 working slide-over panels and dialogs.

A case only goes to the four-eyes check with no open screening hits, no unresolved changes, a written rating rationale and the required approvals requested.

Two reminders, an RM call, final notice, partial and full restriction, then exit review - each with a waiting period, and compliance manager approval before any restriction or exit.

24 retail, corporate and private customers, 24 review cases across 3 campaigns, 19 trigger events, 14 ladder states and a 9-factor risk model.

Reviews Without a Record of Change

The AMLO expects customer due diligence to be kept up to date. Review files in a Word template could not show what had changed since the last review, where the new data came from, or why the risk rating stayed the same.

Triggers Between Reviews

Adverse media, a new address, unusual activity or a change in directors can arrive any day. Each one has to be triaged: open a review, merge it into an open case, bring the periodic review forward, or dismiss it with a reason.

Ownership Behind Corporate Customers

Corporate customers range from sole proprietorships to holding companies with offshore parents. Beneficial owners above 25% have to be traced through intermediate companies, and the significant controllers register is kept by the company, not filed publicly.

Non-Responders Treated Fairly

The HKMA has told banks not to de-risk customers wholesale. Customers who never reply need reasonable notice, help channels, a check for vulnerability and a documented approval before any restriction or exit - and no customer message may hint at suspicion.