From banking
Activate for: CDD, EDD, customer due diligence, enhanced due diligence, simplified due diligence, KYC, know your customer, customer onboarding, source of wealth, source of funds, PEP, politically exposed person, beneficial ownership, UBO, corporate structure, ongoing monitoring. NOT for: personal finance advice or retail banking product recommendations, tax compliance or tax residency determinations, credit underwriting decisions.
npx claudepluginhub panaversity/agentfactory-business-plugins --plugin bankingThis skill uses the workspace's default tool permissions.
Required for all customers at account opening:
Guides implementation of customer identification, due diligence, beneficial ownership collection, enhanced due diligence, risk rating, and KYC monitoring under FINRA Rule 2090, CIP, and FinCEN CDD Rule.
Activate for: KYC risk rating, customer risk classification, AML risk score, customer risk assessment, high-risk customer, risk-based approach, risk rating, customer due diligence risk score, PEP risk, geographic risk, product risk, customer risk categories. NOT for: transaction monitoring alerts (use aml-typologies), SAR/STR drafting (use aml-sar-drafting), sanctions screening (use sanctions-screening).
Performs periodic customer refresh by re-verifying due diligence to detect material changes and maintain AML compliance. Triggers: time-based reviews, risk escalations, event alerts like sanctions.
Share bugs, ideas, or general feedback.
Required for all customers at account opening:
Documents (in order of reliability): Tier 1 (highest): Passport; national ID card; government-issued photo ID Tier 2: Driving licence; residence permit Address verification: Utility bill, bank statement, government correspondence (must be dated within 3 months) For non-face-to-face onboarding: certified copies; electronic verification; video identification (where jurisdiction permits).
Company: Certificate of incorporation; memorandum and articles of association; latest audited accounts; register of directors; register of shareholders Beneficial owner: Identify all individuals owning or controlling ≥ 25% (FATF threshold — some jurisdictions use lower: 10% in USA for certain entities) Director verification: Verify identity of all directors with day-to-day control Authorised signatories: Verify identity of all authorised signatories
Document: Nature of business; anticipated transaction types, volumes, and values; source of funds for specific transactions; geographic profile of activity. Risk-proportionate: More detail required for higher-risk customers and products.
Individuals entrusted with prominent public functions:
Tier 1 — Foreign PEP: Individual holding prominent function in foreign country. Mandatory EDD under FATF. Highest risk. Tier 2 — Domestic PEP: Individual holding prominent function in the bank's home country. EDD required under 5AMLD (EU) and most jurisdictions. Moderate-high risk. Tier 3 — International Organisation PEP: Senior officials of international organisations. EDD required under 5AMLD. Moderate risk. Family members and close associates: Treated as PEPs for EDD purposes.
PEP status does not automatically end when the individual leaves office. FATF guidance: risk-based approach — senior positions warrant longer post-tenure treatment. Minimum: 12-month post-tenure review period. Best practice for senior officials (heads of state, senior ministers): 2–5 years. Bank must document why the individual's risk has reduced to non-PEP level before downgrading their status.
a) Senior management approval (minimum: Head of Business, often CRO level) b) Source of wealth — understand how the individual accumulated their wealth (not just source of funds for this transaction) c) Source of funds — specific source of funds for this relationship/transactions d) Enhanced ongoing monitoring — more frequent and more detailed transaction review e) Annual or more frequent risk review of the relationship
Source of wealth: How did this person accumulate their total net worth? Evidence: Business ownership documents; pay slips; investment records; inheritance documentation; property sales; prior wealth disclosures. Source of funds: Where do the specific funds entering this account come from? Evidence: Bank transfer confirmations; investment sale proceeds; salary receipts. Both are required for PEPs and high-risk customers. Vague assertions ("business income") without documentary evidence are NOT sufficient for EDD.
Permitted in limited circumstances where risk is demonstrably low:
All customer relationships require ongoing monitoring:
For complex corporate structures (holding companies, trusts, foundations): Look through the corporate layers until you identify the natural person(s) who ultimately own or control the customer entity.
Cayman Islands, BVI, Panama, Isle of Man, Jersey, Guernsey: register of members may be private. The bank must still obtain BO information. Options: Obtain certified copy of private register from registered agent; obtain written declaration from customer with supporting documentation; where documentation cannot be obtained: CANNOT onboard or must apply enhanced risk mitigation with documented rationale.
Identify: Settlor; trustee(s); protector(s); beneficiaries (or class of beneficiaries). Verify: Identity of all controlling parties and beneficial owners of > 25%.
ALL OUTPUTS REQUIRE REVIEW BY A QUALIFIED PROFESSIONAL BEFORE USE IN REGULATORY FILINGS OR BUSINESS DECISIONS.