Anti Money Laundering Process
As a regulated financial services company, SS&C Hubwise is required to carry out identity checks on its customers to help prevent financial crimes such as money laundering and identity fraud. Historically SS&C Hubwise have adopted a “reliance” model meaning we relied on the customer due diligence undertaken by the advice businesses using the platform.
Given the evolving nature and complexity of financial crime, SS&C Hubwise, in consultation with the regulator and external consultants, now conduct our own AML verifications for new investors added to the platform. The move to a “non-reliance” model is in line with other platforms in the market and provides our partner firms and investors greater assurance in the robustness of our AML controls.
Please note this does not affect your own AML regulatory obligations. More information on the FCA’s polices and guidance in relation to financial crime can be found on the link below:-
https://www.fca.org.uk/firms/financial-crime
Where applicable, new investors will be verified through automated electronic ID&V checks using the Smart Search platform. Additional supporting information will be requested as part of the Investor and Application creation journeys.
As a result of the verification checks, the Investor(s) status will initially be recorded on the Portal as:-
- Verified or
- Referred
Where the Investor passes these checks, the account can be activated and contributions can be received/ matched. In this scenario, SS&C will invest at the next valuation point.
If the Investor is not verified by the Smart Search platform, their status will show as Referred and an email notification will be issued to the Adviser’s registered email address, advising of the ID&V (identity and verification) documents to be uploaded to the Portal.
Once the documents are uploaded, the Investor status will change to Waiting for authorisation and SS&C Hubwise will review the documentation and update accordingly.
As a result of the review, the status will be updated to Verified, Referred if further information is required, or Failed if evidence is not received or insufficient. Again, an email notification will be issued to the Adviser.
If an investor is deemed high risk, Enhanced Due Diligence checks may be necessary. Additional documents, such as source of funds and Source of Wealth evidence, may be required. Until this documentation is received, money-out transactions will not be permitted.
The AML status of investors (if Referred or Failed) have been added to the existing bank verification report within the Company Reports area of the Portal. The report is now named “Bank AML Referrals”.
Retail Clients
All new retail investors will be verified through automated electronic ID&V checks using the Smart Search platform. This includes the primary account holder as well as all joint holders and associated parties, such as Employers, Beneficiaries, Power of Attorney’s, Executors etc. All parties will need to have a ‘Passed’ AML status to fully activate the account.
Where the Investor passes these checks, the account can be activated and contributions can be received/ matched. In this scenario, SS&C will invest at the next valuation point.
Associated 3rd Parties
Where a 3rd party is an individual, they will be required to go through AML checks, for example beneficial owners/ POA/ Executors. Directors of employers will not go through these checks unless there is a concern identified.
Non-Retail Clients
For non-retail investors, e.g. Corporate Clients & Trusts, the AML checks will initially be completed by the SS&C Hubwise internal operations teams. As with retail clients, we will notify you of any referred cases and request additional evidence to be submitted. It is important to select the correct Corporate Sub-types on the Portal at the Investor Creation stage, as the documentation requested will vary depending on the chosen category. We are looking at a future Portal update to enhance the process for these account types.
Please note - AML checks will be undertaken on the first application for a product on the SS&C Hubwise Portal for the new investor. Subsequent product applications will be covered under the AML status of the initial application.
A separate exercise will be undertaken in early 2025 to carry out AML verification of existing investors on our platform as at 16th December, 2024.
These changes will apply to the following products on the SS&C Hubwise platform:-
- SS&C Hubwise ISA
- SS&C Hubwise GIA
- SS&C Hubwise JISA
- SSS&C Hubwise SIPP
- Countrywide onshore bond
- RL 360 offshore bond
- 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 7 business days.
- Money / Transfers Out - These will be restricted until AML checks are satisfactorily completed.
- SIPP transfers in - Transfers will not be accepted until AML is passed.
- ISA/ GIA transfers in (Cash or In-specie) will continue to process as usual.
An automated email will be sent to the registered Adviser email address where a Referred status is returned.
The notification email will be sent from [email protected] and have the following title – AML Refer - Request further information.
If the relevant supporting documents, detailed on the following page, are not received, a chasing email will be sent after seven days with a second chasing email sent after 14 days. After 21 days, if no supporting documentation has been received, the AML status will be set to Failed.
Following an AML check on a new investor, we will notify the adviser when
- The initial AML check results in a referral and request for additional information.
- When this subsequent AML check results in a pass or referral
Unlike Bank Verification notifications, there are NO notifications sent to the end Investor.
An AML Icon is available to select on the Client’s Global View screen, showing the AML status of the Investor and allowing the uploading of any required evidence.
You are also able to view the AML status by selecting the new AML Details option under All Account Actions for the required Account.
Details of the upload process and related AML screens on the Portal follow in this guide.
In order for client money to be invested at the earliest valuation point, we recommend action is taken as soon as you receive a notification of a referred AML check. You are also recommended to check the AML status after submitting an online application and/ or checking the Bank AML Referrals report.
For retail investors, acceptable ID&V documentation is as follows. One document from each list will be required.
Evidence of personal identity
- Current signed passport
- Current signed UK / EEA photo-card driving licence (full or provisional), or blue disabled driver’s pass.
- Current full UK driving licence (old paper version). Paper provisional licences are not acceptable.
- Recent evidence of entitlement to state or local authority funded benefit, including housing benefit and
council tax benefit or state pension (dated within the last year)
- Most recent HM Revenue & Customs (HMRC) tax coding notification, assessment or statement
- Shotgun or firearms licence
- Residence permit issued by the Home Office
- National identity card
- Northern Ireland voter’s card
- Self-employed registration cards for individuals and partnerships in the construction industry:
CIS3 (partner); CIS4 (P); CIS4 (T); CIS5; CIS6
Evidence of address
Please note the full address must be stated for the document to be acceptable.
- Local authority tax bill (valid for current year)
- Current signed UK / EEA photo-card driving licence (full or provisional)
- Current full UK driving licence (old paper version). Paper provisional licences are not acceptable.
- Solicitor’s letter confirming house purchase or land registry confirmation.
- Local council rent card or tenancy agreement.
- Recent evidence of entitlement to a state or local authority funded benefit, including housing benefit and
council tax benefit or state pension (dated within the last year)
- Original utility bill, no older than 3 months (not including mobile phone bill), or a certificate from a supplier of
utilities confirming the arrangement to pay for the services on pre-payment terms. Note, if your client does not receive paper copies, original PDF colour copies of utility bills are acceptable.
- Most recent HM Revenue & Customs (HMRC) tax coding notification, assessment or statement
Please note that we only accept UK Clients. A non-UK address will not be allowed in the Portal.
We will accept certified copies of original documents. We will also accept an attestation stating, “I confirm I have seen the original documentation and any photograph is a good likeness of the Investor”. The attestation needs to be added to the copy of the ID&V document or as a separate document referencing the ID & V document. Commonly created as Word document signed by advisers (or whoever has seen the original docs).
Getting Started
On accessing the Portal, you will be taken to the Dashboard screen below.
For Users with no linked Investor or Account details (e.g., Admin staff) the Dashboard will show as below.
Now select the Main Menu icon at the top of the screen.
From the ribbon shown select the Investors menu.
Then either Dashboard/Manage or Investor Accounts.
Dashboard/Manage allows you to search for any Investor on the Portal whether they have any in-force Accounts or not. Selecting the Investor will take you to their Global Overview.
Investor Accounts allows you to search for an individual Account. The Account must be in-force to be visible here. Select the Globe button on the right to access the Investor’s Global Overview.
You can access the Review Investor AML Dashboard from the Firm Access menu. This shows a list of all AML checks performed against individuals and their status.
There are filters at the top of the screen so that individuals with a particular AML status can be displayed together, such as Waiting for Documents, Waiting for Authorisation and Verified. There is also an Account ID search option if a specific account is required.
To check the AML status of the client or begin the document upload process, select either the AML icon in the top-left of the screen to see the AML status of the individual or the All Account Actions cog in the bottom right of the required Account, to see the AML status of all individuals linked to the account.
Investor AML Status
The Investor AML screen displays the current AML status of the chosen Investor. Where documentary evidence is required to progress the AML checks these can be uploaded by selecting Upload Documents from the Action drop down.
The Account AML screen displays the AML status of all AML verifiable individuals linked to the account and their AML status. This can be accessed by selecting All Account Actions, next click on AML Details.
The AML account status will be shown with all AML verifiable individuals linked to the account and supporting evidence can be uploaded where required.
Where the Investor AML status is Referred, the status of “Waiting for Documents” will be shown. Selecting Upload Documents under the Actions dropdown displays the screen below. This provides links to the documents required and further guidance on the SS&C Hubwise AML process.
The Upload Documents option allows the relevant supporting documents to be uploaded in either PNG, JPG or PDF format. Multiple documents can be uploaded.
Please upload the required documents as detailed earlier in this guide.
Note: The review process for AML documentation has an SLA of 3 working days..
Once the relevant documents have been selected, click on Accept to upload.
Once documents are uploaded, these will be submitted to the SS&C Hubwise Financial Crime Prevention team for review and the Investor’s AML status on the Portal will now change to “Waiting for Authorisation”.
The SS&C operational teams will review the evidence provided and contact you if any further information is required. Once checks are complete, the status will show as Verified if the documents are acceptable as below, or Failed, if not. If further information is required, the status will return to Waiting for Documents, with a notification sent to the Adviser.
Frequently Asked Questions
Please see the related AML FAQ document in The Knowledge Base
SS&C Hubwise - Anti Money Laundering FAQ’s : Knowledgebase Hubwise
Web Release including AML – 04/12/2024 : Knowledgebase Hubwise
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