What the adviser pack leaves to your own checks
Which checks the Financial services pack does not run, from credit-bureau and sanctions screening to investment performance, and how to record yours.
By Achekam · · 4 min read · For Financial services businesses in South Africa, Nigeria, Kenya
Launching soon. The Industry CRM add-on described in this article is launching soon. This article describes it as it will work at launch.
Software that holds client records invites an easy assumption: if the client is in the system, somebody must have checked them. With Achekam's Financial services pack, that assumption would be wrong in several specific ways. It is far better to know exactly where the line falls before a reviewer, a regulator or a client asks.
This article sets out what the pack leaves to the practice's own processes, why, and how to use the pack to record what those processes found.
No credit-bureau, sanctions or prominent-person checks run by the pack
The pack runs no credit-bureau check, no sanctions screening and no check for prominent or politically exposed persons. It does not connect to a bureau or a screening service, and it does not compare client names against any list.
What it provides instead is a checklist that records the check your own compliance process made. The division of work is deliberate. The screening is done through whatever service or procedure your practice uses, under your practice's responsibility, and the pack holds the result where it belongs, on the client's record. Investopedia's guide to know-your-client checks is a plain overview of what such a process involves, from identity and due diligence to ongoing monitoring, and how it fits with anti-money-laundering rules.
This is worth saying plainly to new staff. A client who appears in the pack has not been screened by the pack. If the checklist is blank, nobody has recorded a check.
Recording the check your process made
A record of a screening check is only useful if it answers the questions someone will later ask. For each check, record:
- What was checked: bureau, sanctions, prominent-person, or another check your process requires.
- How: the service or procedure used.
- When: the date of the check.
- Who ran it.
- Result: clear; a possible match and how it was resolved; or a match and what the practice decided.
- Evidence: where the report or printout is filed.
Fill the checklist in at the time of the check, not afterwards from memory, and make sure the person ticking the box is the person who saw the result. A tick entered by an assistant on the strength of a corridor conversation is worth very little.
When a check turns up a match
Most screening comes back clear. The checks that matter are the ones that do not. Decide in advance what happens when a sanctions or prominent-person check produces a possible match: who looks at it, how quickly, and who has the authority to decide whether the practice proceeds. Record that decision on the checklist with its reason, not just the word "resolved". If the practice decides not to proceed, record that too, and keep the evidence. A file that shows a match was found, examined and decided on by a named person is a far stronger file than one that shows nothing at all.
No investment performance or provider feeds
The pack shows no investment performance. Every asset value is as the client states it, and nothing is read from product providers or lenders. There is no feed from an investment platform, no policy value collected from an insurer, and no loan status read from a bank.
That shapes what the household record can be used for. It is a record of what the client told you, at a date. It is not a portfolio report, and it should never be shown to a client as one. The same applies to loan applications: what a lender has said reaches you from the lender, and you record it.
Why stated values are labelled as stated
Labelling a value as the client's statement protects everyone. The client knows the figure came from them. The adviser does not appear to vouch for a number nobody verified. A reviewer can see where every figure came from.
When a value matters to your advice, obtain the provider's statement and file it next to the household review, with its date beside the value. If the client's figure and the statement disagree, record both and the reason, if you know it.
Keeping evidence of each check on file
The pack's records are only as strong as the evidence behind them. Store screening reports, provider statements and the client's own documents in Document Centre, in the client's folder. It is a folder-based store with versions, tags and search, so evidence can be found quickly when someone asks for it. Each stored file gets a SHA-256 fingerprint, which gives you a fixed reference for the file as it was stored.
Use tags for the kind of evidence, such as "sanctions check" or "provider statement", so that a reviewer asking to see every screening report for a period can be shown them without a search through each client.
Who does what
| Task | The pack | Your practice |
|---|---|---|
| Credit-bureau check | Records the result on its checklist | Runs the check |
| Sanctions screening | Records the result on its checklist | Runs the check |
| Prominent-person check | Records the result on its checklist | Runs the check |
| Asset values | Holds what the client states | Obtains provider statements where needed |
| Investment performance | Shows none | Uses provider reports |
| Reviews and loan applications | Tracks them through their stages | Does the advice and origination work |
Each industry pack sets the words, records, workflows, document requests and reminders for its own trade. The Financial services pack sets them for financial advisers and bond originators, with these limits written in rather than hidden.
The annual cycle that relies on stated values is described in running the annual household review, and the lender side in tracking a loan application milestone by milestone.
Write a paragraph setting out how your practice screens new clients and where the results are filed. That paragraph is what turns the pack's checklist into a record a reviewer can rely on.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
