When you enrol a client for ongoing Anti-Money Laundering (AML) monitoring in EngageAML, the system checks the client's identity details against our screening provider. Sometimes this check does not return a clear pass, which means ongoing monitoring is not switched on for that client. This does not mean the client failed the Know Your Customer (KYC) check — KYC and AML monitoring are checked separately, so a client can be KYC Verified even if their AML monitoring check has not passed.
Common reasons the AML monitoring check does not pass
There are a few common reasons an AML monitoring check does not pass:
Incomplete identity details — if the client's date of birth or gender is missing or incorrect, the screening provider may return false matches or an 'Under Review' result. These fields are now required when you enrol a client, to help prevent this issue.
A possible match requiring review — the screening provider may flag a possible match against a Politically Exposed Person (PEP) list, sanctions list, adverse media, or another individual with a similar name and date of birth. Results like this need manual review before monitoring can be enabled.
An AML fail result — in some cases the screening provider returns a stronger adverse result. When this happens, monitoring stays switched off pending review.
What you'll see in EngageAML
If the AML monitoring check for a client does not pass, you'll see the following in EngageAML:
On the engagement's AML step (Step 6), the client's status shows as 'Under Review' or 'AML Failed' and the ongoing monitoring toggle is switched off.
A banner displays stating that the AML monitoring check did not pass.
What to do next
If a client's AML monitoring check has not passed, follow these steps:
Confirm the client's KYC status shows as 'Verified.' KYC verification and AML monitoring are separate checks, so a client can be KYC Verified even if their AML monitoring check has not passed.
Check that the client's or ultimate beneficial owner's (UBO) date of birth and gender are entered correctly. Incorrect identity details are the most common cause of a failed monitoring check.
If the details are correct and the status hasn't changed, contact our support team for a review.
Ongoing monitoring only switches on once a clear result is returned. If you correct identity details, the client will need to be re-screened.
This is different from
A failed AML monitoring check is different from the following, which are checked and managed separately:
KYC Verified or KYC Failed status
Client due diligence (CDD) tier
Engagement letter or terms of engagement templates