REQ reporting with InScope-AML – 2021

The below is a brief overview of the various sections of the REQ. This is intended to ensure that our customers are able to find pertinent information and ease the reporting burden. It is not, however, intended to provide guidance on how to answer said questions or interpretations of definitions. In such cases clients should always refer to guidance issued by The Regulator.

If you require assistance or cannot locate any of the information below, please feel free to contact our support team and we will be happy to explain further.

The REQ’s can be found here

Early Sections

These sections contain questions around the following:

• Subject Person
• Governance
• The Business Risk Assessment
• Customer Acceptance
• De-risking controls
• Ongoing Monitoring
• Policies and Procedures
• Internal Audit
• Reporting
• Training
• Record Keeping
• De-risking inherent risk

These sections request information that is not normally stored in InScope-AML and therefore there is no applicable guidance.

Customer Information

Most Service information can be found under the Services section of the main reports dashboard, if you have such information stored in the system.

Breakdowns of clients by various subdivisions (I.e New client onboardings, occasional transactions, etc and associated information like associated jurisdictions) can be found by clicking on the number of clients that you have provided the relevant service to.

For questions relating directly to your entity, such as directorships held, you can only find this information in InScope-AML if you have created your own entity within the system and have added your entity to the relevant structures. The information will then be on the Entity Profile page, under ‘Roles’

For most other questions related to this category, information will be captured in Custom fields (if at all), and therefore can be located under the ‘Clients by Custom Fields’ Tab of the reporting section of InScope-AML.

Information on structures including Trusts, Organisations etc can be found under the Main Reports Dashboard, under the Complex Structures section

N.B – FIAU definition of ‘Offshore’

In this year’s REQ, the term ‘Offshore Vehicles’ is used, the definition of which is below. The reports tab in InScope-AML has a complex structures section which references the EU – Non-Cooperative Tax Jurisdictions, this is in line with the regulators guidance.

A percentage breakdown of your client base by Risk Classification and the various risk brackets are both available on the homepage of InScope-AML.

For questions that are hyper-specific, such as:

• UBO’s that have used IIP/Residency programmes
• Criminal conviction of UBO’s or;
• Whether or not the subject person holds funds in trust

These sorts of questions are not ubiquitous across our client base, and therefore are not implemented ‘Out of the box’. As such these will be dealt with via Custom Field.

In InScope-AML, information that is captured in Custom Fields can be located under ‘Clients by Custom field’ for Serviced entities, or ‘UBO’s by Custom Fields’ for UBO’s.

If this information is stored in your InScope-AML setup, it may require a specific segment to be created if not stored in a custom field.

If you do not have the information in a custom field please contact Support (support@04a.57d.myftpupload.com) for assistance in creating the necessary custom fields/ segment

Geographic risk

Information required for the  Jurisdictional questions will be captured in ‘Clients by related Countries’, and can be located under the Clients by Related Countries Tab of the reporting section of InScope-AML. This of course will depend on the information currently being captured via your ‘Related Country Types’

Most other information required for Geographical/Jurisdiction Risk questions can be found on the main reporting Dashboard, via the ‘Domicile of UBO’s’ and Domicile of Client’s reports, there is also pertinent information in the client breakdowns (accessed when you click the number on the reports dashboard.

Also InScope-AML’s reporting now includes a report on companies with subsidiaries, denoted by jurisdiction, in order to assist with this year’s reporting. (N.B This may require an additional segment to be setup, please contact support if you would like to know more.)

Interface / Distribution Channels

For questions relating to Interface and Distribution channels, InScope-AML has various sections of the main reports dashboard that are dedicated to capturing this information.

Questions regarding face-to-face and non face-to-face client percentages can be found under the interface section, and information relating to jurisdictions of intermediaries can be located under Reports dashboard -> Delivery channels

There is also a section for the domicile of introducers on the main dashboards, per the below image.

More specific questions may be available if captured in a Custom Field via ‘Clients by custom fields’

Conclusion
Whilst we have done our utmost to provide the best guidance possible, we always recommend deferring to any and all guidance produced by The FIAU.

If we can assist you with your InScope-AML setup or any further questions you can contact support here.