SS&C Hubwise - Anti Money Laundering changes

Dear client

As part of our commitment and investment to address the evolving challenges of financial crime, SS&C Hubwise is changing the way it manages its Anti-Money Laundering (AML) responsibilities.  

From 9 December, 2024 we will conduct our own AML verifications for new investors added to the platform.  This change will provide our partner firms and investors greater assurance in the robustness of our AML practices, associated processes and control. The FCA remains focused on strengthening AML controls and having taken external advice, we believe the market is moving in this direction.

A separate exercise will be undertaken in early 2025 to carry out AML verification of existing investors on our platform as at 9 December, 2024.

Please note this change does not affect your own AML regulatory obligations.

What this means for you:

Retail Investors:

• All new retail investors will be verified through automated electronic ID&V checks using the SmartSearch platform
• Most investors are expected to pass these checks. However, if a check fails, we will request certified copies of original documents for identity verification, which you will need to upload*  
• If an investor is deemed high risk, Enhanced Due Diligence will be necessary. Additional documents, such as Source of Wealth information, may be required. Until this documentation is received, money-out transactions will not be permitted  

 *The attached document provides a high-level overview of the process, along with a list of accepted documents

 Non-Retail Accounts (eg Corporates/Trusts): 

• AML checks for these accounts will primarily be manual. However, if a check fails, we will request certified copies of original documents for identity verification, which you will need to upload*
• We will enhance our portal in December/January to streamline the process by collecting additional required information

Portal Enhancements:

The Portal will be enhanced to capture the required information for the completion of a customer risk assessment.  This new feature will include a drop-down menu of mandatory fields for:

• Job Role
• Employment sector
• Salary Range
• Reason for Investment
• Source of funds (at investment)

Impact on Transactions until AML verification completed:

• Transfers In (Cash or In-specie): No impact - these will process as usual
• New Monies: Deposits will not be allowed until AML checks are complete including the provision of any requested documents.  Any incoming funds will remain in our Client Money Account and, if unresolved, will be returned via the ‘Return to Remitter’ process within a set timeframe
• Money Out and Transfers Out: These will be restricted until AML checks are satisfactorily completed

Thank you for your ongoing support and understanding that these are necessary enhancements to our Platform. 

As we get closer to the date, we will issue further updates but if, in the meantime, you have any questions, please raise a Freshdesk ticket.

Kind regards,

Anil Dala

Deputy Managing Director