If your firm already has AML/CTF documents, you can upload them to Firm Verify instead of generating them with a wizard. The upload steps are the same for a Risk Assessment, Policy, Process and Program.
How to upload a document
| Step | What you'll see |
|---|---|
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1
Go to Firm > Program. |
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2
Select Upload, then select the document type: Risk Assessment, Policy, Process or Program. The upload window opens. |
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3
Complete the fields and attach your files. See Fields. |
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4
Select Save. |
Fields
| Field | Required | Notes |
|---|---|---|
| Title | Required | Free text, for example ML/TF/PF Risk Assessment. |
| Version | Required | Free text, for example 1.0. |
| Summary of Changes | Optional | What changed in this version. |
| Mark as Reviewed | Optional | Tick this if the document has already been reviewed and approved in your firm. Date Reviewed, Reviewed By and Next Review Due then appear. |
| Date Reviewed | Conditional | Required when Mark as Reviewed is ticked. Can't be a future date. |
| Reviewed By | Conditional | Required when Mark as Reviewed is ticked. Select from your users and key personnel. |
| Next Review Due | Conditional | Required when Mark as Reviewed is ticked. Must be a future date. |
| Documents | Required | Select the upload area or drag and drop your files. |
What happens after you save
| If you… | Status |
|---|---|
| Save with Mark as Reviewed ticked | Approved |
| Save without Mark as Reviewed, then select Send for Review | Under Review |
| Save without Mark as Reviewed, then select Cancel | Draft |
Frequently asked questions
Select a question to see the answer.
We already have an AML/CTF program. Do we need to use the wizards?
No. Upload your existing documents using the steps above. Before you upload your risk assessment, check the Please note at the top of this article: it explains how an uploaded risk assessment affects Initial CDD.
Is the upload the same for every document type?
Yes. The fields, saving and review steps are the same for a Risk Assessment, Policy, Process and Program. Only the window title and the document label change.
Our document has already been approved. What do I do?
Tick Mark as Reviewed and complete Date Reviewed, Reviewed By and Next Review Due. The document saves as Approved, so you don't need to send it for review.
Can I edit a document after I upload it?
You can edit a Draft document from the ⋮ menu. Approved and Under Review documents are locked.
Related articles
To build your documents in Firm Verify instead, see Generate a Risk Assessment, Generate a Policy and Generate a Process. To assemble your program, see Create your AML/CTF Program. For how your risk assessment is used with clients, see Initial Client Due Diligence.