How it works

Learn how AML screening and monitoring works.

AML is triggered for the applicants that are currently approved. If you approve a rejected applicant manually, you need to initiate a new AML check using this API method. If the applicant was approved by the system, the AML check will be performed as described below.

Data extraction

There are two types of watchlist screening:

  • Information-based. Textual data, such as the applicant name and date of birth received from the applicant is matched against a comprehensive set of watchlists in order to find/exclude a match.
  • Document-based. The name and date of birth are extracted from the identity document that was uploaded by the applicant.

In both cases, fuzzy logic is involved to ensure that no spelling variations of the applicant’s name are overlooked.

Watchlist screening

The watchlist screening helps find applicants that are:

  • Known or suspected terrorists
  • Sanctioned persons
  • Politically exposed persons (PEPs)
  • Persons with criminal background
  • Persons mentioned in adverse media

The potentially matching data from various sanctions and watchlists is compared against the applicant profile to establish a match. Below you will find a list of matches available in Sumsub.

Match typeDescription
True positiveApplicant data exactly matches one or several watchlist records. Full DOB of the applicant along with their name matches one or several watchlist records, but middle name omitted/abbreviated.
Potential matchName of the applicant matches one or several watchlist records, but the age/year of birth data is missing or the applicant is suspected of committing a crime. When two of three words in the applicant name match one or several watchlist records, along with their year of birth or age.
False positiveApplicant data doesn't match the source, or it matches, but the context clearly shows the person doesn't pose any threat.
UnknownApplicant name in the document contains only one word. There can also be cases with the matching applicant common name and abundance of matches. In such tricky cases the Sumsub client makes the final decision regarding the applicant.

Match processing

Applicants with False positive statuses are automatically approved; all the rest are either declined or assigned the Requires action status and then delegated to the client compliance officers for further processing.

Here are some examples:

CaseStatusNext action
The applicant name is not found in any of the sources.N/AThe applicant is automatically approved.
Applicant data exactly matches in one or several watchlist records.True positiveThe applicant is either declined or assigned the Requires action status and then delegated to the client compliance officers for further processing. The action depends on the customer settings.
Applicant data matches the watchlist record, but the record does not include criminal or suspicious information about the person. For example, if the applicant is a crime journalist, and their name features on the article as an author.False positiveThe applicant is assigned the Approved status.
Applicant data matches the watchlist record exactly, but additional information clearly shows that the applicant and the person on the record are different people.False positiveThe applicant is assigned the Approved status.
Name of the applicant matches one or several watchlist records, but the age/year of birth data is missing, or the applicant is suspected of committing a crime.Potential matchThe applicant is assigned the Declined status or Requires action status and then delegated to the client compliance officers for further processing.
The applicant name contains just one word.
There can also be cases with the matching applicant common name and abundance of matches.
UnknownThe applicant is assigned the Declined status or Requires action status and then delegated to the client compliance officers for further processing.

Examples:

  • False positive. The applicant name match one or several watchlist records, but their DOB/age is different.
  • True positive. The applicant name partially matches one or several watchlist records and DOB/age matches these too, but the middle name is abbreviated.
  • Potential match. Two of three words in the applicant full name match one or several watchlist records, and their DOB/age matches these too.

If applicants are declined based on a watchlist match, they are assigned a respective rejection tag depending on the source where the match was found:

  • Sanctions
  • PEP
  • Criminal records
  • Adverse Media
  • On demand, the system can be set to delegate borderline cases to the client compliance officers for manual processing.

Adverse Media categories

General tags

Subcategories

FATF & EU AML Directive 22 predicate offences

Adverse Media General

General AML/CFT

  • Bribery

  • Graft

  • Kickbacks

  • Political corruption

  • Organized crime

  • Criminal association

  • Racketeering

  • Smuggling (excl. drugs, money, people or guns/weapons/arms)

  • Poaching

  • Illegal logging

  • Animal cruelty

  • Corruption

  • Other environmental crime

  • People smuggling

  • Migrant smuggling

  • Smuggling of animals

  • Illegal pollution/waste

  • GMigrant trafficking

  • Sanctions violation/risk/connection

  • Tax-related smuggling

Adverse Media Financial Crime

Financial AML/CFT

  • Money laundering

  • Insider trading

  • Tax-related offenses

  • FTax evasion

  • Market manipulation

Financial Difficulty

  • Bankruptcy

  • Financial difficulty

  • Unexpected resignation of CFO

  • Layoff /retrenchments/furloughs

  • Store closures

  • Late payment to creditors

Other Financial

  • Loan sharking

  • Usury

  • Predatory lending

  • Questionable billing practices

  • Non-specific financial crime

  • Tax avoidance (not illegal)

  • Creative accounting

Adverse Media Narcotics

Narcotics AML/CFT

  • Drug trafficking

  • Drug distribution

  • Drug production

  • Drug dealing

Adverse Media Fraud

Fraud-linked

  • Fraud

  • Scams

  • Swindles

  • Counterfeiting

  • Forgery

  • Identity theft

  • Impersonation

  • Mortgage fraud

  • Identity fraud

  • Corporate fraud

  • Electronic fraud (E-fraud)

  • Misrepresentation

  • VAT fraud

  • Counterfeiting currency

  • Residential fraud

  • Non-specified fraud

Adverse Media Violent crime

Violence AML/CFT

  • Kidnapping

  • Abduction

  • Held against the will

  • Murder (Committed, planned, or attempted)

  • Child pornography

  • People trafficking

  • Organ trafficking

  • Arms trafficking

  • Homicide

  • Assassination

  • Coercion

  • Child sexual abuse

  • Pimping

  • Sex trafficking

  • Human trafficking

  • Slavery

  • Sexual exploitation (incl. of children)

  • Grievous bodily harm/injury

  • Illegal restraint

  • Hostage-taking

  • Extortion

  • Robbery

  • Child trafficking

  • Illegal possession of guns, weapons, or explosives

  • Illegal sale of guns, weapons, or explosives

Adverse Media Violence NON AML/CFT

  • Rape

  • Sexual abuse

  • Pedophilia

  • Assault

  • Battery

  • Domestic abuse

  • Elder child abuse

  • Physical abuse

  • Domestic violence

  • Molestation

  • Sexual harassment

  • Purposeful transmission of HIV

  • Human rights abuses by state and non-state actors

  • Genocide

  • War crimes

  • Massacres

  • Torture

  • Illegal pornography

  • Manslaughter

  • Other violent crime

  • Other sexual crime

Adverse Media Terrorism

Terrorism

  • Terrorist-related

  • Member of a terrorist organization

  • Terrorist attack

  • Terror/terrorist financing

  • Aiding of terrorists/terrorism

  • Cyberterrorism

  • Political terrorism

  • Terroristic oppression

Cybercrime

  • Computer-related cybercrime

  • Illegal access to information systems

  • Illegal system interference

  • Illegal data interference

  • Illegal interception

Other crimes

Adverse Media Other Serious

  • Perjury

  • Obstruction of Justice

  • False filings

  • False statements

  • Fugitive

  • Election interference

  • Escaped from imprisonment

  • Arson

  • Spying

  • Espionage

  • OTreason

  • Civil disorder

Adverse Media Other Minor

  • Possession of drugs

  • Possession of drug paraphernalia

  • Illegal prostitution

  • Misconduct

  • Vandalism

  • False advertising

  • Drug possession

  • Labour abuse

  • DUI (Driving under the influence)

  • Health & safety issue

  • Human resource issue/dispute

  • Litigation

  • Security related issue

  • Minor-sounding, difficult-to-classify offences

  • Non-specific crime

  • Conspiracy for a non-specific crime

Adverse Media Regulatory

  • Antitrust

  • Price fixing

  • Illegal gambling

  • Forfeiture

  • Denied entity

  • Anti-competitive issues

  • Product dumping

  • Regulatory issues

  • Regulatory breach

  • Greenmail

  • Churning

  • Regulatory fines

  • Collusion

  • Industry sanctions/fine /discipline

  • Securities violations