Product updates

A compliance officer role for the firms we work for

A firm we run checks for can have a compliance officer of its own, invited by the practice doing the work. The role settles who signs a case off and who takes the certificate, rather than everyone at the firm being able to do both.

An invitation does not switch the permission on. We confirm the person first, and their rights begin from that point. That is slower on purpose: an invitation on its own should not be able to hand over a sign-off right.

Sign-off goes to the firm's compliance officer

Where a case needs sign-off, it goes to that officer rather than to a second reviewer at the practice. Where the practice is the firm, sign-off stays where it was. On the firm's own list, cases waiting on the officer are counted on their own.

None of it runs one way. The practice can take a case back out of sign-off before it is decided, and the officer can return it for changes with a reason, or decline. Each is a decision with a name and a time against it, and all of them land in the case's notes among the messages the two sides have already written there.

The case list can be read by customer

The case list now opens by customer: each customer named once, with their matters under them, so a firm acting for the same customer across several matters sees those together instead of scattered through the list by date. It can be switched back to a flat list of cases, and whichever was chosen last is the one that opens next time.

A matter filed under the wrong customer can be moved to the right one from the list.

A related party is assessed as part of the case above it

A related party opened from an entity's ownership now says which case it belongs to, at the top of its own view, with a way back to that case.

It is not scored, not summarised and not signed off on its own. The assessment sits with the case at the top and reads the related party's facts as part of its own, so there is one rating for the entity rather than one for each person behind it. Signing off that case carries its related parties with it.

Consent is asked of people, not of entities

A case opened on a company, a trust or any other entity no longer asks for agreement to terms. The people behind the entity agree on their own cases, where the question is theirs to answer.

Nothing changes in what a person is asked. The same documents, the same checkboxes, the same alternative if they would rather not do it online.

The client is told which firm is asking

Where a client is being asked for something, the firm asking is named. Where the message is a confirmation or a statement of where things stand, it names nobody and says what happens next instead.

We are not the party asking, so our own name appears in neither.

An amount is read as it is written, or refused

Where a client types an amount, it is read as digits, with an optional currency sign, thousands separators and up to two decimals. Anything else is refused while the client is still on the screen, and they are asked to write the figure out.

Shorthand is not interpreted. A figure written as 1.5M is not turned into 1,500,000. Every shorthand accepted brings its own way of being read wrong, and the number ends up on the certificate.

An entity case can be opened without a client email

A firm doing the entity checks itself does not have to supply a client email to open the case. The address is needed at the point something is actually sent to the client, not before.

It can be added later from the case, when there is something to send.

Source of wealth sits beside source of funds

Beside each source of funds a client declares there is now a note on where that money originally came from. It is collected while the client is already there, rather than asked for separately once someone decides it is needed.

A request can be answered with more than one document

A client asked for evidence, or answering a request for information, will be able to attach several documents rather than one. Most requests are answered with several.

Documents that arrive in answer to a request will be read the same way as documents that arrive anywhere else.

A trust deed and the variations that follow it

A trust is rarely one document. There is the deed, and then the variations that change who is involved. The most recent governs, and all of them have to be on record.

The deed and its variations will be read together, so the people named are the people involved now. Earlier deeds will have a place of their own, held as a record rather than read.

Correcting what a client has already sent

A client types a figure wrongly or attaches the wrong document, and at present the firm cannot put either right. Both will be correctable from the case.

What was first submitted does not disappear. A correction will be an act with a person and a time against it, not a silent overwrite.

Company and trust shareholders carry through the register lookup

A register lookup keeps shareholders that are companies or trusts, with their holding, alongside individuals. Each one at 25% or more becomes a related party with its own case, opened with what the register gives about it already filled in, so ownership can be followed layer by layer.

The case shows every party and register holder in one place, as a tree with each one's status and the action it needs. Holders not being verified are listed as well, with a note where the holding is 25% or more or the role is a control role.

The case list can be taken out as a spreadsheet

A firm reporting on its own work can take the case list out as a spreadsheet instead of retyping it from the screen. Export CSV on the list downloads the rows it is showing, with its filters and order. A row is a case, carrying what the list shows: the matter, the reference, the risk, where the case has got to and what it is waiting on. The customer's name is added so a case can be recognised without opening it, and a last column, Comment, is left empty to write in.

The reporting entity's staff have the same button on their list, with the columns that list shows.

The file is built from a named set of fields rather than from whatever the case record happens to hold, so nothing beyond those columns arrives in the spreadsheet.

The case note is open to the reporting entity's staff

Staff at the reporting entity can read and write the note on the case, alongside the person it is assigned to and the reviewer. The client does not see it, it stays off the certificate and out of the audit trail, and it is left out when the case is printed.

Each note carries the name of the person who wrote it and the organisation they wrote it from, both recorded at the time of writing, so a later change of name or role does not rewrite who said what. Three parties can be in one thread, so what is shown beside a name is the organisation rather than a role on the case.

Notes written before this opened to them as well. Those were written on the understanding that two people would read them, so it was agreed with the design partner before it was turned on rather than after.

Seeing which cases have changed

The reporting entity's case list and case pages show where each case has got to and whose turn it is: the stage it is at, such as Identity, SOF or Evidence, and whether it is waiting on the customer or with the firm doing the work. A case waiting on the customer also says when the customer's link has expired, or when it is the related parties who still have to respond.

A bell at the top of the page lists the cases with something new since you last opened them, and says what: a new note from the firm doing the work, a status update (sent for sign-off, returned, approved, declined, put on hold, resumed, archived or brought back), or a new case. Notes written by your own organisation are not counted. Progress inside a stage shows on the list rather than in the bell. Opening a case clears it, and Mark all as read clears the lot. Counting starts from when the bell was introduced or when you were given access, whichever is later, so the list does not open full of older cases. Nothing is emailed and nothing pops up.

The bell is for the reporting entity's staff. The people working the case already see this on their own case list.

The entity screen states what the entity owns

What an entity owns now sits alongside what it earns. Each class of asset is listed with its cost, accumulated depreciation and net book value, and the assets acquired or disposed of during the year are listed one by one.

The lines are taken from the columns the schedule prints rather than summarised from them, and the figures are checked twice: against the total at the foot of the schedule, and against the fixed asset figure on the balance sheet. The screen names the figure it reconciled with and the page it came from.

Most statements do not itemise assets at all, and for those the screen says nothing rather than warning every time. Where a schedule is there but the figures could not be confirmed, the screen says which check did not pass.

A private note between the two people working the case

A note on the case, open to the person it is assigned to and the person reviewing it, and to nobody else. Each entry carries who wrote it and when, and the author can go back and change or remove their own.

It is deliberately not a record. Nothing written here reaches the certificate or the audit trail, and none of it is shared with the reporting entity or the client. Decisions, escalations and sign-off reasons go where they have always gone.

Putting a case on hold

A case can be put on hold while it waits on something the firm cannot move. Its related parties are held with it. While it is on hold nothing on the case can be changed, it leaves the counts of cases waiting on a client, and no further requests can be sent.

The client link keeps working, and a client who opens it is told the case is paused rather than being refused at the point of submitting. Holding a case is open to the person it is assigned to, while the case is still open, and the same person can resume it.

Archiving a case now works the same way: the case and its related parties are set aside together, and the case can be brought back.

Client email states the matter and the obligation

The email names the matter the client is dealing with, states that the firm cannot complete it until the checks are done, and says the checks apply to every client rather than being a judgement about this one.

Consent screen states what is asked for and the offline alternative

Above the checkboxes the client sees what will be asked for, and what the alternative is if they would rather not do it online: originals sighted in person, or certified copies by post.

The legal documents, the checkboxes and the biometric consent are unchanged.

Risk breakdown opens two levels deep

Rules under each category are open on arrival. Expand all and Collapse all sit in the Risk breakdown header, and the choice persists between visits.

Identity document images are retained and shown

The front and back images of the identity document are retained. They appear at the top of the identity section, in the document drawer, and in the archive a firm downloads for itself.

Where an image cannot be retrieved within the provider's window, the identity section says so and offers a retry while retrying can still work.

One notification per request

Recording a requirement and notifying the client are separate actions, so requesting several things sends one email rather than one per requirement.

Sending a client link is limited to the person the case is assigned to, and is refused once the case has been signed off or closed.

Financial statements are collected and read at entity onboarding

The entity screen has a second document slot for financial statements, alongside the company extract.

The document is read for reporting period, basis of preparation, assurance and signatories; revenue, result, assets, liabilities and net assets against the prior year; and related party transactions and balances, each quoted with the page it came from. Fields the document does not state are shown as not stated rather than as blank or zero.

Requirements are set when the case is opened

Requirements derive from the firm's own programme, now by entity type as well as matter type. The case creation screen lists what the case will collect before anything is sent, and source of funds can be switched off there. Identity cannot.

A requirement switched off at case open can be added later from the case, so the decision is not final.

Source of funds asks about the funds in this matter

The question asks where the funds going into this matter came from, and says so on the screen: not the client's other savings or assets.

Sources are ordered by matter type. Six are shown for a property purchase and the remaining fifteen sit behind a disclosure. Each source names the document required for it.

Reaching clients by phone

Not doing this yet, for two reasons. A verification link arriving by text cannot be distinguished from a phishing message by the person receiving it, and the phone number on file is entered by the firm with no verified source behind it.

Overdue flags and reminders on the existing email link come first, to establish whether the channel or the silence is the problem. If it is the channel, this is a swap on an existing flow rather than a rebuild.

Consent screen presents the documents themselves

The terms, the privacy policy and the consent disclosure notice are presented as documents, each with its own checkbox, and the request carries the name of the firm asking rather than ours.

Part of a case can be delegated to the client's adviser

Requirements the client's accountant or adviser holds can be sent to that person directly. Identity and consent stay with the client and cannot be delegated, and nothing can be delegated before the client has consented.

The case list states what each case is waiting on

Each row states what the case is waiting on. The filters and the counts above the list derive from the same reading, so they cannot disagree with the row.

In-person identity flow starts at the same step as remote

The disclaimer screen written for the practitioner is no longer shown to the client. Both routes start at the same step.