Subject sharing based on consent

July 24, 2023 KYC Portal CLM is built bearing the single customer view in mind. The ability to collate the data, documents, questionnaires and screening data for a subject once, irrespective of how many times that subject is involved under different structures and services. This leads to reduced costs of managing duplicate data and documents, but also leads to a faster onboarding rate since the same subject is not required to upload the same information multiple times.
The concept of the single customer view in KYCP works in different instances allowing for both the scenarios where the compliance team actually searched the subject prior adding them as well as the scenario that the team was not aware of this subject being in the database already. These are achieved using the following two functions:
  • USE FROM EXISTING – when adding a subject in KYCP, the system allows you to create the new subject by using an existing one in the database. The user can search for the subject (using any field that is of type string, integer or decimal), see and confirm the subject and then click on USE SUBJECT. This will create the new subject using all the linked fields of choice, documents that are set to move with the subject across applications as well as any other common data such as notes and screening matches and decisions. 
  • IDENTIFICATION ALERT – in the case that a user was not aware that such subject existed in the database and did not perform the search, the solution will automatically alert a potential duplicate match alert when trying to save the new subject, for which the data being input matches that of another existing subject. The user is then prompted with an alert allowing them to match the details of the existing subject in the database with the data of the new subject being input. User is then free to decide whether to resume saving with the existing data, the new data or create from scratch completely.
This functionality comes in very handy when the operations of the company using KYC Portal CLM spans over multiple offices in different jurisdictions. Organisations are able to create the single customer view irrespective if the subject being onboarded is under different services across the globe. This gives the company the ability to instantly view all related parties and multiple involvements of subjects across the global operations.
This feature however poses an operational issue when data is shared between programmes that are used for specific jurisdictions. We have instances of clients whereby they wanted the data of all subjects across all jurisdictions to be shared having a single customer view, however, should that subject be in the programme of Luxembourg, then this data cannot be shared with any of the other programmes (jurisdictions). We also have use cases whereby clients saw this feature as a problem as they would need to obtain consent from the subject prior to making their data available for other programmes to re-use.
This new feature addresses the above use cases whilst still allowing for the benefit of being able to have the single customer view. This new feature now allows you to decide at entity level whether the data of such entity should be shared or not.
KYC Portal CLM 
This setting allows the compliance team to set the default state of an entity allowing it to be shared across all programmes, only within the same programme or else not shared at all. This addresses the ability of having KYCP setup to share the data across programmes but being able to limit the entities of one programme only from being shared at all or only within the same programme they already exist in.
This new feature however, also allows you to set conditions with such a setting based on a field or set of field values.
KYC Portal CLM 
This feature has been based on keynames so that clients can setup all of the conditions based on preferred values within such fields. A field could be set stating “I consent my data to be shared” which field can also be exposed / sent to the customer for them to fill it in directly.
What happens if a subject exists but is not shared based on the above new feature?
  • Identification will still be alerted to the user that there is a duplicate in the system, however, when the user clicks on the VIEW details icon to see the data of the existing entity, if such entity is not set to be shared the user will not be allowed to click on it and be informed accordingly. 
  • Based on the configuration of the programmes, SEARCHING for this subject or USE FROM EXISTING for the same subject will still show the subject in question. However, there are various means how this (SEARCH and USE FROM EXISTING) can also be managed/limited.
    • Limit user access to the other programmes – this means the user will not be able to find the respective subject in the other programmes that the user does not have access to.
    • Setting the programme not to be included in the “Search in Linked Programmes” feature. In this case all subjects in this programme would not appear in the results of any SEARCH or USE FROM EXISTING
For more information, contact us directly on or schedule your live demo with us today. If you are an existing client and you would like more information about this feature, please contact our CRM Team.
Targeted For Managing counterparties with multiple involvement
Status LIVE
Keywords KYCL, AML, single customer view, consent
Direct Benefits Ability to create the single customer view within KYCP based on the consent given at subject level