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 carried out against a dynamic global database of consolidated profiles including Sanctions, Watchlists, Politically Exposed Persons (PEP), Adverse Media, Warnings, and Fitness.

Onboarding a new entity

Onboarding a client

The Onboarding New Client [link to Mambu webhook] process is automatically triggered when a new client is created via the Mambu UI or API and the Mambu webhook Client Created is sent to the Mambu Process Orchestrator (MPO). This incoming webhook initiates a search in ComplyAdvantage using the client’s full name as the search criteria. Optional search filters such as client country, entity type, and birth year may also be configured to refine the search.

Onboarding a group

The Onboarding New Group Router [link to Mambu webhook] process is automatically triggered when a new group is created via the Mambu UI or API and the Mambu webhook Group Created is sent to the MPO. An API call is made to ComplyAdvantage to perform a search against the group name. Optional search criteria such as group country and entity type may also be used to refine the search.

Outcomes of the search

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

  • For 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.
  • For Potential Match status with search results from AML lists, the results are stored as Boolean values in the following Mambu custom fields: Sanctions, PEP, Adverse Media, Warnings, and Fitness. This only happens if these optional custom fields are set up and available in the Configuration Setup configuration.

Based on the value of Match Status received from ComplyAdvantage and the values provided for customUpdates during the configuration, the connector will carry out the following actions:

ClientGroup
Apply Monitored status in ComplyAdvantage, based on match status from monitoredStatus listApply Monitored status in ComplyAdvantage, based on match status from monitoredStatus list
Receive an AML report in Mambu as a task, based on match status from reportStatus listReceive an AML report in Mambu as a task, based on match status from reportStatus list
Set Blacklisted in Mambu, based on match status from blacklistedStatus and blacklistedSources list

Blacklisted client logic

Blacklisted Client

When there is match status on reportStatus list, a report is created as a task in Mambu for the client or group entity. For example:

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].

Please Note:
The following fields have unique features:

  1. The country field of a client or group can hold one or more country codes. When more than one country code is stored, they must follow the ISO 3166-1 format and use a comma(,) separator, for example, DE,FR,....
  2. Birth date should be in dd-MM-yyyy HH:mm:ss or dd-MM-yyyy format.

Entity management

Client management

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

When an existing client is updated, a comparison is made in MPO based on the aml_clientSearchVersion custom field that stores a hashed version of the criteria used for the last search. A comparison is made between the value stored in the client custom field and the value of the new searchVersion from client details. If changes are detected, a new search will be triggered in ComplyAdvantage using the new client details - client full name, country codes, and birth year (if present) - as the search criteria. The previous search will no longer be monitored in ComplyAdvantage and, if sendUnsubscribeReport is set to true in notification configuration, a notification task is created in Mambu that highlights this change. For example:

> 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

The Group Management Router [link to Mambu webhook] process is automatically triggered when an existing group is updated via the Mambu UI or API and the Mambu webhook Group Activity is sent to MPO.

When the group activity webhook is received, a comparison is made in MPO based on the aml_groupSearchVersion custom field that stores a hashed version of the criteria used for the last search. A comparison will be made between the value stored in the custom field and the value of the new searchVersion from the webhook. If changes are detected, a new search will be triggered in ComplyAdvantage using the new group details as the search criteria. The previous search will no longer be monitored in ComplyAdvantage and, if sendUnsubscribeReport is set to true in notification configuration, a notification task is created in Mambu that highlights this change. For example:

> 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.

Outcomes of updated search

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 Search Id, Match Status, Share Url, and Risk Level Mambu custom fields and new values are added for Sanctions, PEP, Adverse Media,Warnings, and Fitness based on the Configuration Setup configuration.
  • From Potential Match to No Match: search results are updated in the Search Id, Match Status, Share Url, and Risk Level custom fields and existing values from Sanctions, PEP, Adverse Media, Warnings and Fitness custom fields are updated.
  • From No Match to No Match: search results are updated in the Search Id, Match Status, Share Url, and Risk Level custom fields.
  • From Potential Match to Potential Match: search results are updated in the Search Id, Match Status, Share Url, and Risk Level custom fields and the Sanctions, PEP, Adverse Media, Warnings and Fitness custom fields are updated based on the Configuration Setup configuration.

Based on the Match Status value received from ComplyAdvantage and Custom Updates configuration, the client or group can automatically:

ClientGroup
Apply Monitored status in ComplyAdvantage, based on match status from monitoredStatus listApply Monitored status in ComplyAdvantage, based on match status from monitoredStatus list
Receive an AML report in Mambu as a task, based on match status from reportStatus listReceive an AML report in Mambu as a task, based on match status from reportStatus list
Set Blacklisted in Mambu, based on match status from blacklistedStatus and blacklistedSources list

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

> 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.

Entity management by event

The Entity Management Router [link to ComplyAdvantage webhook] process is automatically triggered when an existing search for a person, company, or organisation in ComplyAdvantage is updated via the following webhooks: Search Status Updated, Monitored Search Updated, or Match Status Updated. The purpose of this process is to decide if the update applies for a client (person) or a group (company or organisation). If the entity type received in MPO is invalid then the error message is stored in the Error Handling -[AML] state diagram.

Monitored Search Updated and Match Status Updated webhooks

The Monitored Search Updated webhook is triggered when a monitored search has been detected as having updated search results available, the suspended state of the monitored search changes or both scenarios occur. The Match Status Updated webhook is triggered whenever the match status of an entity or the is_whitelisted property of an entity is changed. Through these webhooks the PEP, Adverse Media, Sanctions, Warnings, and Fitness custom fields are updated in Mambu.

Based on the new values received from ComplyAdvantage and Custom Updates configuration, the client or group can automatically set Blacklisted in Mambu based on match status from blacklistedStatus and blacklistedSources list.

Search Status Updated webhook

The Search Status Updated webhook is triggered via UI or API by changing Match Status, Risk Level, or Assigned To. It also updates the values for these custom fields in Mambu. Based on the new Match Status value received from ComplyAdvantage and Custom Updates configuration, the client or group can automatically:

ClientGroup
Apply Monitored in ComplyAdvantage based on match status from monitoredStatus listApply Monitored in ComplyAdvantage based on match status from monitoredStatus list
Receive an AML report as a task in Mambu based on match status from reportStatus listReceive an AML report as a task in Mambu based on match status from reportStatus list
Set Blacklisted in Mambu based on match status from blacklistedStatus and blacklistedSources list
Set Whitelisted for a Blacklisted client based on match status from whitelistedStatus list

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

> 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 the 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.

Please Note:

  1. The Match Status and Risk Level fields can only be updated via the ComplyAdvantage API.
  2. A Blacklisted client is Whitelisted to the defaultClientState set for the tenant. This can be either active or inactive.
  3. For Blacklisted clients, if match status is not in the whitelistedStatus list, the client will remain Blacklisted and the custom field value will be changed.

Whitelist client logic

Whitelisted Client

Stop monitoring clients

The Stop Monitoring [link to Mambu webhook] process is automatically triggered when an existing client is transitioned to an inactive state via the Mambu UI or API and the Mambu webhook Client Activity is sent to MPO. Inactive states include Blacklisted, Rejected, or Exited.

Please Note:

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

When a client is transitioned to an inactive state, the ComplyAdvantage search is no longer monitored and the client details are saved in Reactivate unmonitored clients state diagram. The following opt-in notifications are applicable only when client monitoring is stopped:

When option exists 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
exitedClient: monitored stopped in ComplyAdvantageexitedClient: payload is ignored in MPO

Stop monitoring groups

The Group Management Router [link to Mambu webhook] process is automatically triggered when the aml_stopMonitoring custom field of a group is set to EXITED from the Mambu UI. This will lead to the ComplyAdvantage search no longer being monitored and the group details are saved in Reactivate unmonitored groups SD.

When option exists in stopMonitoringOnEvent listWhen option doesn’t exist in stopMonitoringOnEvent list
exitedGroup: monitored stopped in ComplyAdvantageexitedGroup: payload is ignored in MPO

Re-activate unmonitored searches in CA for clients and groups

The Client Management [link to Mambu webhook] and Group Management [link to Mambu webhook] processes are automatically triggered when a previously exited, rejected, or blacklisted (with comment) client is reverted from this state or an exited group custom field is removed in Mambu. The Mambu webhook Client/Group Activity is sent to MPO.

After receiving the webhook, the flow will search for the specific client or group in Reactivate unmonitored clients/groups SD and if the client or group is found, the process will continue with re-activating the existing search in ComplyAdvantage.

Upstream onboarding for clients

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 to MPO from an upstream process. The client is created in Mambu via API, only after screening is done in ComplyAdvantage.

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

The client will be created in Mambu based on the value of createUpstreamBlacklistedClient in your Custom Updates configuration.

createUpstreamBlacklistedClient = FALSEcreateUpstreamBlacklistedClient = TRUE
match_status is in blacklistedStatus or blacklistedSources lists, the client is not createdmatch_status is in blacklistedStatus or blacklistedSources lists, the client is created
match_status is not in blacklistedStatus or blacklistedSources lists, the client is createdmatch_status is not in blacklistedStatus or blacklistedSources lists, the client is created

Please Note:

The birth date for client creation must be provided in the format yyyy-MM-dd.

When the property createUpstreamBlacklistedClient is set to false and isBlacklisted is set to true, a Mambu task or Zendesk 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.

Actions that will be taken based on the value of Match Status stored in Custom Updates configuration include:

Client:

  • Applying Monitored status in ComplyAdvantage (monitoredStatus list)
  • Receiving an AML report in Mambu as a task (reportStatus list)
  • Setting Blacklisted status in Mambu (blacklistedStatus & blacklistedSources lists)

Upstream onboarding for groups

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 to MPO from an upstream process. The group is created in Mambu via API only after screening is carried out in ComplyAdvantage.

ComplyAdvantage uses the group name as the search criteria. For more precise results, optional search filters like country or entity type can be used if they are sent by the upstream process. Based on the value of group type, the group can be created in Mambu under three main types: company, organisation, or group (default).

The groupType IDs are:

  • For company, the group is created under the company group type
  • For organization, the group is created under the organization group type
  • For any other value or an empty value forPotentialMatch, the group is created under the first Entity Type sent by ComplyAdvantage search results (organization or company)
  • For any other value or an empty value forNoMatch, the group is created under the default group type, group |

Notifications

For negative flows, if notification was set to true, a task will be created in Mambu, Zendesk, or sent to another other specified URL provided during configuration, with a specific error message. The client or group details like name, ID, and other data necessary for any manual intervention regarding monitoring, blacklisting, and sending reports are also mentioned in the task message.