Business Flows

This template allows you to use ComplyAdvantage’s Anti-Money Laundering (AML) Screening and Monitoring feature for checking the risk profile of Clients and Groups. Screening is done against the world’s only dynamic global database - including Sanctions, Watchlists, Politically Exposed Persons (PEP), and Adverse Media - in consolidated and structured profiles.

1. Onboarding a New Entity

Onboarding a Client

Onboarding New Client

The Onboarding New Client [link to Mambu webhook] process is automatically triggered when a new Client is created via the Mambu UI, API or the Mambu webhook Client Created is sent in Mambu Process Orchestrator (MPO).

When a new Client is created via the API or UI a search is triggered in ComplyAdvantage using the client’s full name as the search criteria. Optional search filters like client country, entity type and birth year may also be used.

Onboarding a Group

Onboarding New Group

The Onboarding New Group Router [link to Mambu webhook] process is automatically triggered when a new Group is created via the Mambu UI, API or the Mambu webhook Group Created is sent in MPO. The purpose of this process is to decide which route should be followed in MPO based on the Group configuration (with or without the entityType custom field). If the entity type received is invalid the error message is stored in the Error Handling -[AML] state diagram.

When a new Group is created via the API or UI a search is triggered in ComplyAdvantage using the group name as the search criteria. Optional search filters like group country and entity type may also be used.

After the search is completed in ComplyAdvantage a Client or Group can have one of the following statuses:

  • No Match status the search results are stored in the following Mambu custom fields in the Client or Group entity: Search Id, Match Status, Share Url and Risk Level.
  • Potential Match status only if optional custom fields were set up and are available in the Setup configuration. The search results from AML lists (Sanctions, PEP and Adverse Media) will also be stored in the following Mambu custom fields: Sanctions, PEP and Adverse Media.

Based on the Match Status value received from ComplyAdvantage and Custom Updates configuration the Client or Group can automatically:

ClientGroup
Set Monitored or not in ComplyAdvantage (based on match status from monitoredStatus list)Set Monitored or not in ComplyAdvantage (based on match status from monitoredStatus list)
Receive an AML report in Mambu as a task (based on match status from reportStatus list)Receive an AML report in Mambu as a task (based on match status from reportStatus list)
Set Blacklisted or not in Mambu (based on match status from blacklistedStatus & blacklistedSources list)

Blacklisted Client Logic

Blacklisted Client

When there is match status on reportStatus list the following report as a task is created in Mambu for the Client or Group entity.

Please check client AML report and search result in AML custom fields. Client Search Reference: [1594823671-s5zaXunN] with Match Status: [potential_match].

Please check group AML report and search result in AML custom fields. Group Search Reference: [8994845690-s9yaZenN] with Match Status: [no_match].

Notes:

  1. One or many country codes can stored under the Client or Group country field. When multiple country codes are stored they must follow the ISO 3166-1 format and use a comma(,) separator (e.g: DE, FR, etc.).
  2. Birth date should be in dd-MM-yyyy HH:mm:ss or dd-MM-yyyy format.

2. Entity Management

Client Management

Client Management

The Client Management [link to Mambu webhook] process is automatically triggered when an existent Client is updated via the Mambu UI, API or the Mambu webhook Client Activity is sent in MPO.

When an existent Client is updated via the API or UI a comparison is made in MPO based on aml_clientSearchVersion custom field that stores the criteria based on which the last search was made - in a hashing algorithm form. The comparison is made between the value stored in client custom field and the value of the new searchVersion from client details. This decides if a new search should be triggered in ComplyAdvantage using the new client details - Client Full Name, Country Codes and Birth Year when exists - as the search criteria. The previous search will no longer be monitored in ComplyAdvantage and a notification task is created in Mambu that highlights this change.

Client details were changed. Please add a comment in ComplyAdvantage to highlight this change. Initial Client Search ID: 328875813 with Match Status: potential_match was stopped to be monitored. Please check client and new search result in AML custom fields. Client new Search Reference: 1591799274-Ndhd3Y4L with Match Status: no_match.

Group Management

Group Management

The Group Management Router [link to Mambu webhook] process is automatically triggered when an existent Group is updated via the Mambu UI, API or the Mambu webhook Group Activity is sent in MPO. The purpose of this process is to decide which route should be followed in MPO based on the Group configuration (with or without entityType custom field). If the entity type received is invalid then the error message is stored in Error Handling -[AML] state diagram.

When an existent Group is updated via the API or UI a comparison is made in MPO based on aml_groupSearchVersion custom field that stores the criteria based on which the last search was made - in a hashing algorithm form. The comparison will be made between the value stored in group custom field and the value of the new searchVersion from group details. This decides if a new search should be triggered in ComplyAdvantage using the new group details as the search criteria. The previous search will no longer be monitored in ComplyAdvantage and a notification task is created in Mambu that highlights this change.

Group details were changed. Please add a comment in ComplyAdvantage to highlight this change. Initial Group Search ID: 333346738 with Match Status: true_positive was stopped to be monitored. Please check group and new search result in AML custom fields. Group new Search Reference: 1592566702-5OHxQqUL with Match Status: no_match.

After the new search is completed in ComplyAdvantage the following Client or Group match status transitions can occur:

  • From No Match to Potential Match status -> search results are updated in the following Mambu custom fields on the Client or Group entity: Search Id, Match Status, Share Url and Risk Level and new values are added in Mambu custom fields Sanctions, PEP and Adverse Media based on the Setup configuration.
  • From Potential Match to No Match-> search results are updated in the following Mambu custom fields on the Client or Group entity: Search Id, Match Status, Share Url and Risk Level and values from custom fields Sanctions, PEP and Adverse Media are removed (if exists).
  • From No Match to No Match -> search results are updated in the following Mambu custom fields on Client entity: Search Id, Match Status, Share Url and Risk Level.
  • From Potential Match to Potential Match -> search results are updated in the following Mambu custom fields on the Client or Group entity: Search Id, Match Status, Share Url and Risk Level and new values are updated in Mambu custom fields Sanctions, PEP and Adverse Media based on the Setup configuration.

Based on the Match Status value received from ComplyAdvantage and Custom Updates configuration the Client or Group can automatically:

ClientGroup
Set Monitored or not in ComplyAdvantage (based on match status from monitoredStatus list)Set Monitored or not in ComplyAdvantage (based on match status from monitoredStatus list)
Receive an AML report in Mambu as a task (based on match status from reportStatus list)Receive an AML report in Mambu as a task (based on match status from reportStatus list)
Set Blacklisted or not in Mambu (based on match status from blacklistedStatus & blacklistedSources list)

When there is match status on reportStatus list then the following report as a task is created in Mambu for the Client or Group entity.

Please check client AML report and search result in AML custom fields. Client Search Reference: [1594904335-6AWvrDXo] with Match Status: [potential_match]. Initial Client Search ID: [346736029] with Match Status: [no_match] was stopped to be monitored.

Please check group AML report and search result in AML custom fields. Group Search Reference: [7894904335-8VWvrHYu] with Match Status: [no_match]. Initial Group Search ID: [946723001] with Match Status: [potential_match] was stopped to be monitored.

3. Entity Management by Event

Client Management by Event

Client Management by Event

The Entity Management Router [link to ComplyAdvantage webhook] process is automatically triggered when an existent search (person or company/organisation) in ComplyAdvantage is updated via the UI or API by changing the Match Status, Risk Level or Assigned To and the webhook Search Status Updated is sent. The purpose of this process is to decide if the update applies for a Client (entity person) or a Group (entity company/organisation). If the entity type received in MPO is invalid then the error message is stored in Error Handling -[AML] state diagram.

Group Management by Event

Group Management by Event

When Match Status is updated for an existent Client or Group in ComplyAdvantage the MPO process Entity Management Router [link to ComplyAdvantage webhook] is triggered and only the value for Match Status custom field in Mambu is updated.

Based on the new Match Status value received from ComplyAdvantage and Custom Updates configuration the Client or Group can automatically:

ClientGroup
Set Monitored or not in ComplyAdvantage (based on match status from monitoredStatus list)Set Monitored or not in ComplyAdvantage (based on match status from monitoredStatus list)
Receive an AML report in Mambu as a task (based on match status from reportStatus list)Receive an AML report in Mambu as a task (based on match status from reportStatus list)
Set Blacklisted or not in Mambu (based on match status from blacklistedStatus & blacklistedSources list)
Set Whitelisted for Blacklisted client (based on match status from whitelistedStatus list)

When there is match status on reportStatus list then the following report is created as a task in Mambu that highlights Match Status updates.

Please check Client AML report and search result in AML custom fields. Match Status changed from [no_match] to [potential_match].

Please check Group AML report and search result in AML custom fields. Match Status changed from [potential_match] to [true_positive].

When Risk Level is updated for an existing Client or Group in ComplyAdvantage the MPO process Entity Management Router [link to ComplyAdvantage webhook] is triggered and only value for Risk Level custom field in Mambu is updated.

When Assigned To is updated for an existing Client or Group in ComplyAdvantage, the MPO process Entity Management Router [link to ComplyAdvantage webhook] is triggered, but the webhook payload is Ignored and no changes are made in the Mambu UI.

Notes:

  1. The Match Status and Risk Level field can only be updated at once via the ComplyAdvantage API.
  2. Blacklisted client is Whitelisted to defaultClientState set on the tenant, to active or inactive.
  3. For Blacklisted client, if match status is not from whitelistedStatus list, the client will remain Blacklisted, the Custom Field value can not be changed. This is a Mambu core limitation.

Whitelist Client Logic

Whitelisted Client

4. Stop Monitoring

The sequence diagram below explains the logic of this use case.
Stop Monitoring

The Client Stop Monitoring [link to Mambu webhook] process is automatically triggered when an existent Client is transitioned in one of the following invalid states: Blacklisted, Rejected or Existed via the Mambu UI or API and Mambu webhook Client Activity is sent in MPO.

When a client is transitioned to one of the above invalid states, in ComplyAdvantage that search is not monitored anymore. The following opt-in notifications are applicable only when client monitoring is stopped:

When option exist in stopMonitoringOnEvent listWhen option doesn’t exist in stopMonitoringOnEvent list
blacklistedClient -> monitored stopped in ComplyAdvantageblacklistedClient -> payload is ignored in MPO
rejectedClient -> monitored stopped in ComplyAdvantagerejectedClient -> payload is ignored in MPO
existedClient -> monitored stopped in ComplyAdvantageexistedClient -> payload is ignored in MPO

Note: When a client is transitioned to Blacklisted state from Mambu UI a comment must be added.

For negative flows if the notification was set to true then a task will be created in Mambu or ZenDesk based on the configuration of Notification Setup, with a specific error message in order to be analyzed. The Client or Group details like name, ID and data needed for manual interventions over monitoring, blacklisting and sending report are also mentioned in the task message.

5. Upstream Onboarding New Entity

Upstream Onboarding Client

Upstream Onboarding Client

The Upstream Onboarding New Client process is automatically triggered when Mambu is being used with a Digital Engagement layer or a Customer Origination layer, and Client details are sent in MPO from upstream process. The Client is created in Mambu (via APIs) only after screening is done in ComplyAdvantage.

ComplyAdvantage uses the client’s full name as the search criteria. For more narrow results optional search filters like client country, entity type and birth year (format allowed: yyyy) can be used if they are sent by an upstream process.

Based on the createUpstreamBlacklistedClient value stored in Custom Updates configuration the Client can be created or not in Mambu:

createUpstreamBlacklistedClient = FALSEcreateUpstreamBlacklistedClient = TRUE
match_status is in blacklistedStatus or blacklistedSources lists –> Client is not createdmatch_status is in blacklistedStatus or blacklistedSources lists –> Client is created
match_status is NOT in blacklistedStatus or blacklistedSources lists –> Client is createdmatch_status is NOT in blacklistedStatus or blacklistedSources lists –> Client is created

Note: Birthdate format allowed in Mambu APIs for Client creation is yyyy-MM-dd.

When property createUpstreamBlacklistedClient is set to false and isBlacklisted is set to true a task/notification is sent with the following notification message:

The Upstream Client was not created in Mambu due to a Custom Update configuration option [createUpstreamBlacklistedClient] which is set to [false]. Client [Lopez Pena Julio Cesar] with ID [false_true_PM] was searched in ComplyAdvantage with matchStatus = [potential_match]. ComplyAdvantage search details: searchId = [369433629], searchRef = [1599124770-LYBoxons], shareUrl = [https://app.complyadvantage.com/public/search/1599124770-LYBoxons/a91d9e946d07] and riskLevel = [unknown]. Task was created from MPO for Process ID: 11658.

Based on the Match Status value stored in Custom Updates configuration the Client can automatically:

Client
Set Monitored or not in ComplyAdvantage (monitoredStatus list)
Receive an AML report in Mambu as a task (reportStatus list)
Set Blacklisted or not in Mambu (blacklistedStatus & blacklistedSources lists)

Upstream Onboarding Group

Upstream Onboarding New Group

The Upstream Onboarding New Group Router process is automatically triggered when Mambu is being used with a Digital Engagement layer or a Customer Origination layer, and Group details are sent in MPO from upstream process. The Group is created in Mambu (via APIs) only after screening is done in ComplyAdvantage.

ComplyAdvantage use the group name uses as the search criteria. For more narrow results optional search filters like group country or entity type can be used (if are sent by upstream process).

Based on the Group Type value the Group can be created in Mambu under three main types: company, organisation, or group (default type).

groupType ID
company -> Group is created under company group type
organisation -> Group is created under organisation group type
any other value/empty value forPotentialMatch -> Group is created under the first Entity Type sent by ComplyAdvantage search results (organisation or company)
any other value/empty value forNoMatch -> Group is created under default group type group

When group type is not company,organisation or it is empty then a task or notification is sent based on the chosen Notification option with one of the following notification messages:

Group was created in Mambu under DEFAULT group type, due to Group Type ID [partnership] is different than allowed values [company] or [organisation]. Search was done in ComplyAdvantage for Group Name [organisation_groupid_empty] with ID [organisation_groupid_empty], Group Search ID [367863145] and Search Reference [1598881590-xAuQ2czI]. For Match Status [no_match] no [entityType] is stored from ComplyAdvantage search results. Please check group and search result in AML custom fields.

Group was created in Mambu under Group Type Id [organisation] due to Group Type ID [partnership] is different than allowed values [company] or [organisation]. Search was done in ComplyAdvantage for Group Name [MEHR IRAN CREDIT UNION BANK] with ID [company_groupid_invalid3_PM], Group Search ID [367881185] and Search Reference [1598883757-zke22SYM]. For Match Status [potential_match], [entityType] retrieved from ComplyAdvantage search results is [organisation]. Please check group and search result in AML custom fields.

Group was created in Mambu under DEFAULT group type, due to Entity Type sent by ComplyAdvantage [vessel] is different than allowed values [company] or [organisation] for Group Type ID []. Search was done in ComplyAdvantage for Group Name [SARINA] with ID [VESSEL_test4], Group Search ID [367899240], Search Reference [1598886213-9Ibk0JVy] and Match Status [potential_match]. Please check group and search result in AML custom fields.