THE CUSTOMER LIFECYCLE
Onboarding is today. Compliance is for a lifetime.
Onboarding happens once. Keeping a customer compliant lasts for as long as the relationship does. Here is what First Mile Labs does at each stage, with an honest label on each: live today, in early access, or coming next.
THE DUTY
The duty doesn’t end at approval
FATF Recommendation 10 asks firms to keep up due diligence for as long as a business relationship lasts, and the UK’s Money Laundering Regulations 2017 require ongoing monitoring of every business relationship: scrutinising what the customer does, and keeping what you know about them up to date. A platform that stops at the approval leaves that work to spreadsheets and calendar reminders.
STAGE BY STAGE
Six stages, one platform
Set up
Early accessFrom the risk policy you already have
Upload the risk calculator you already use. The AI drafts your risk model, asks where your spreadsheet is ambiguous and shows how your past cases would have scored. Your team confirms every setting, and a second approver signs it off before anything goes live. Without it, our team sets up your workspace with you: your vendors, jurisdictions, document requirements and risk model.
Read more →Onboard
LiveBusiness and personal customers, on your rules
Business and personal customers apply through a link with your branding, or upload their company documents and confirm what the AI reads from them. The platform checks the company against registries, maps who owns and controls it, verifies the people behind it, and asks only for the documents your rules require for that jurisdiction and entity type.
Read more →Decide
LiveYour risk model and rules: AI recommends, people decide
Every person and company in a case is screened for sanctions and PEPs, and the case is scored on your own risk model. With a decision policy, cases that meet your criteria are approved automatically; the rest reach an analyst with the evidence assembled. An AI review can recommend approve, refer or decline with a memo, and a person or your policy makes the call.
Read more →Monitor
LiveRe-screened at the cadence each risk band needs
Every approved customer is enrolled in monitoring at the cadence their risk band sets: by default weekly for critical risk, monthly for high, quarterly for medium and yearly for low. Each run re-screens the company and its people for sanctions and PEPs, and you can switch on registry refresh and document-expiry alerts. Alerts go to the case owner, and to your systems by webhook.
Read more →Review
ComingPeriodic review and refreshed customer details
Periodic review is coming: a review date set by risk band, the customer confirming or updating their details, the checks re-run where they need to be, and a second person signing the review off. Today, monitoring review cases (Lift and above) give confirmed monitoring hits that four-eyes treatment.
Exit
ComingEnd the relationship, keep the record
Ending a relationship is coming: a recorded exit with a reason, monitoring stopped, and the record-keeping clock started for you.
WHEN SOMETHING CHANGES
What happens when a customer’s world moves
A sanctions designation names someone in the ownership chain
The next monitoring run re-screens the company and its people. A new match raises an alert to the case owner, and your analyst resolves or dismisses it. With monitoring review cases on, a confirmed match re-scores the customer and any rise in risk goes to your MLRO.
A director’s passport is about to expire
With document-expiry alerts on, the case owner hears at 90 days, at 30 days and on the day. Sending the re-request automatically is coming.
A new director is appointed
Today, registry refresh flags a change in the company’s status, number of officers or registered address. Telling you exactly who changed, and screening them, is coming.
The customer leaves
A recorded exit that stops monitoring and starts the record-keeping clock is coming. Until then, your team can switch a customer’s monitoring off from their case (Lift and above).
GOVERNANCE
A record your regulator can follow
- Every check, document, note and decision on a case, with who did what and when
- AI recommends and people decide; the AI that runs on its own can be switched off, feature by feature or all at once
- Data subject requests handled per person: we export or erase one person’s data at your MLRO’s request
- Personal data encrypted at rest, and each tenant kept apart
FAQ
Questions about the lifecycle
- What is ongoing due diligence?
- Ongoing due diligence means keeping what you know about a customer up to date, and watching what they do, for as long as the relationship lasts — not only at onboarding. FATF Recommendation 10 asks for it, and the UK’s Money Laundering Regulations 2017 require ongoing monitoring of every business relationship.
- What does First Mile Labs do after a customer is approved?
- Every approved customer is enrolled in monitoring at the cadence their risk band sets. Each run re-screens the company and its people against sanctions and PEP lists, and you can switch on registry refresh and document-expiry alerts. When a run finds something, an alert goes to the case owner for review.
- Does First Mile Labs do periodic reviews?
- Not yet: periodic review is coming. It will set a review date by risk band, ask the customer to confirm or update their details, re-run the checks that need it and close with a second person’s sign-off. Today, monitoring review cases give confirmed monitoring hits that four-eyes treatment (Lift and above).
See the lifecycle on your own policy
Talk to our team about your customers, your vendors and your risk policy.