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SCOPE OF WORK - Brookfields

Checks Requested - AML​

1. Regulatory Enforcement List (REL):​

Screening individuals and entities against databases tracking regulatory violations and enforcement actions. This includes penalties, fines, or sanctions due to non-compliance with laws and regulations.

  • Purpose: To identify risks associated with parties having a history of regulatory violations.

2. Reputational Risk Exposure (RRE):​

Assessment of potential risks based on public reputation and historical behavior, including adverse news, negative media coverage, or past controversies.

  • Purpose: To evaluate reputational risks and enable risk mitigation.

3. Sanctions:​

Comprehensive screening against global sanctions and law enforcement watchlists for both target entities and connected parties.

4. Profile of Interest (POI):​

Examination of individuals or entities exhibiting suspicious characteristics or behaviors, such as unusual transaction patterns or connections to high-risk jurisdictions.

  • Purpose: To enhance due diligence efforts and allocate resources efficiently.

5. Politically Exposed Person (PEP):​

Identification of individuals holding prominent public positions, such as government officials or executives in state-owned enterprises.

  • Purpose: To assess risks related to corruption or misuse of public resources.

6. Politically Exposed Person by Association (PEP Linked):​

Screening individuals closely associated with PEPs, such as family members or business partners.

  • Purpose: To ensure comprehensive risk assessment of PEP relationships.

7. Adverse Media:​

Screening for adverse media coverage on the entity, including media classification, summaries, and timelines.

  • Purpose: To identify potential reputational risks based on media exposure.

Scope of AML Checks​

  1. Entities: AML checks will be conducted on corporate entities.
  2. Directors/Partners/Proprietors: Checks will extend to the directors, partners, or proprietors of the entity. (Only Level 1 Connected Parties)
  3. Connected Parties: AML checks will include connected parties of the corporate entity. (Only Level 1 Connected Parties)
  4. Adverse Media: Screening will be limited to the entity name.
  5. PEP Checks: Conducted on directors, partners, proprietors, and connected parties. (Only Level 1 Connected Parties)

Data Output​

1. Summary of Results:​

  • Data output will provide a list of Total number of directors, connected parties, and signatories associated with the entity.
  • Number of AML hits for each Target.
  • Detailed information on each AML hit, including regulatory violations, reputational risks, sanctions, and PEP details.

2. Sample Data Output:​

REL:​

  • Penalty
  • Category: Financial Regulator
  • ID: 23932918
  • Penalty Details: INR 5,00,000
  • Date: 03 July 2023
  • Language: Eng
  • Credibility: High
  • Datasets: REL, CORP
  • Summary: The Reserve Bank of India (RBI) has penalized TransUnion CIBIL Limited for non-compliance with certain provisions of the Credit Information Companies (Regulation) Act, 2005
  • Original URL: RBI Press Release

RRE:​

  • Court Proceedings in Progress: Sentence - Guilty
  • Categories: Financial Crime and Fraud
  • ID: 22454064
  • Title: Man who duped Portsmouth businessmen into investing over £100,000 for 'lavish lifestyle' avoids jail
  • Date: 22 February 2021
  • Source: Portsmouth News
  • Summary: The subject persuaded his two victims into investing more than GBP 100,000 in foreign trading with information that was inaccurate and continued to provide false WhatsApp messages which claimed a profit. He pleaded guilty to two counts of fraud by false representation and was sentenced to 2 years in jail, suspended for two years, and 20 days of rehabilitation. Source: Portsmouth, 08 February 2021 The source provides personal identification details of the subject. Please refer to the Details section of the profile.
  • Keywords: fraud, charged, guilty, sentenced
  • Data sets: RRE, ID

Sanctions:​

  • Category: Financial Regulator
  • Subcategory: Other - Environment, Labour, Health & Safety, Competition, Consumer, Immigration - Italian Competition Authority (Autorita garante della concorrenza e del mercato, AGCM) - Sanctions (Provvedimenti sanzionatori) - Italy
  • Type: Fine
  • Currency Code: EUR
  • Amount: 500000
  • Evidence Ids: 24448656
  • Date Iso: 2024-05-21

PEP Details:​

  • General Information about the Profile - Sanjay Udan
  • Address
  • Pep Tier - Tier 1
  • Role - Member of Janta Dal United JD(U)
  • Date - 17 July 2021
  • Status - Current/Former
  • Data sets: PEP, PEP-CURRENT, PEP-FORMER

Profile of Interest​

Politically Exposed Person by Association:​

  • General Information about the Profile - Venkatraman Anantharam
  • Address
  • Association: Nephew of Sanjay Udan
  • Pep Tier - Tier 1
  • Role - Member of Janta Dal United JD(U)
  • Date - 17 July 2021
  • Status - Current/Former
  • Data sets: PEP, PEP-CURRENT, PEP-FORMER

Adverse Media:​

Platform Features​

1. Data Presentation:​

  • AML checks will be available to the User on the DART platform.
  • Users can upload entities, place orders, and view results directly on the platform.
  • Data cannot be downloaded as PDFs or Excel files.

2. Team Management:​

  • An organizational account will be created for Brookfields.
  • Admins can add users to the platform.
  • Admins are authorized to place orders, and all users can view results.

3. Credit Management:​

  • Initial Credits: 5,000 credits will be allocated.
  • Credit Usage: Each check deducts one credit. For example, an entity with 3 directors and 2 connected parties will consume 6 credits.
  • Credit History: Credit History will be visible to the user.

4. Bulk Upload:​

  • Users can upload a CSV file containing entity details for AML checks.
  • Required Fields:
    • Corporate Entities: Mandatory Field - Company Name, Optional Field - CIN (Can be used for identifying the company and for matching purpose)
    • LLPs: Mandatory Field - LLP Name, Optional Field - LLPIN.
    • Non-Corporate Entities: Entity Name. If Checks on Proprietor/Partners is required please provide the Individual's Name and Date of Birth for perfect matches. Checks can be run with only Individual name but individual's name without DOB will yield low probable matches.