Control Description
What information is generally not requested from the customer during a business refresh cycle?
What are CDD questions and Source of Wealth (SoW)?
Can thresholds for confirmed PEPs be raised?
What is no, they cannot be raised above a certain amount without CO approval?
Customer has an online business where they teach English, what category level is this business?
Level 1
What are some red flags regarding SOW/SOF documents?
-Document looks off/ fake.
-SOW for the line of business does not make sense.
-Document properties have been changed/ modified.
-Previously rejected documents seem off → only check, if you need to ask new documents.
-Inconsistency between the SOW and the business activities.
Who reviews the case before it reaches SMA?
What is the offshore CDD team?
How far back should an SMA specialist look at past reviews (and comments)?
What is the last 12 months of reviews and if there are 5 or less review comments, all comments should be checked?
Customer recently onboarded his rideshare business based out of Colombia, what business category level is this and would it be within our AUP?
Level 5, and this business would have to offboarded as ridesharing platforms are not allowed outside EEA/EU/US/UK
When it comes to business activity what are some red flags to look out for?
-Online activity: how old is it, is the webpage active, does the information on the webpage match the info given by the customer
-Domain of email address, to determine if the customer is involved with activities against AUP
What qualifies as a "material change" in a business's KYB profile?
What is a significant change in account usage or a change in funding sources (SoF/SoW)?
During SMA BRC when more information is needed what steps will we take?
1. Leave a detailed review comment in Watson, outlining the needed information and the reasoning.
2. Change team back to offshore CDD or whatever team it was initially with and the offshore CDD agent or other will reach out to the customer for the information.
3. Once the customer provides the information, offshore CDD agent will check that customer provided the correct info and change team back to SMA for final review.
Vitamins OU was recently onboarded with Wise based off their website they primary sell basic vitamins and protein powder. What category level is this and is it against our AUP?
Level 3, and no it's not against our AUP as basics vitamins or food supplements don't need a license and don’t make unreasonable claims in terms of treatment
What must we do when we come across red flags?
Be sure to either request documents when possible to find a way to mitigate it. Even when we can't mitigate the risk we always need to notate them in the comments clearly.
When does a Wise business customer in Hong Kong require escalation to SMA for BRC?
What is when their business is registered in Hong Kong and there has been a material change since the original SMA sign-off?
What do SMA specialist need to take a closer look at in regards to sense checking profiles for BRC reviews?
1. Business Information
-Brief sense check of the business, its activities, and if they makes sense.
-Check the evidences provided by the customer (e.g. use case, expected volumes), these should be in line with activities we see on the profile and the business activities.
-SMA specialist is not required to recheck business registration documents.
2. Adverse Media
-Specialist needs to ensure that the adverse media search was performed against all the relevant parties, in all the relevant languages.
For businesses involving chemicals, when would we offboard?
UAE based Oil, Gas & Shipping companies
Bulk chemicals
Toxic chemicals developed for the purpose of terrorism
Chemical weapons / weaponizable chemicals
B2C chemicals companies
As far as transaction history and use case what's a red flag?
intended transactions do not match with the customer’s business activities or use case.
When does a Wise EU business customer require escalation to SMA for BRC?
Customer has touch-points to high risk third country (meaning they are sending and/or receiving funds to/from HR3Cs)
There has been a material change in their KYC profile since the time of the original SMA sign-off. You can find this info easily under evidences "HIGH_RISK_TOUCHPOINT_COUNTRIES“
What is the maximum monthly threshold that PEP would place on an account for Consumer and Business?
30,000 GBP monthly for consumer PEP's.
200,000 GBP monthly for business PEP's.
Tours R Us was recently onboarded. The company provides tours to different locations and gives visitors a local experience. One of their most popular tours involves going to the Amazon for a 5 day Ayahuasca retreat. What level would this business be and is the business within our AUP?
Level 3, and this would be against our AUP as ayahuasca is considered to be a drug.