The list is never ending… but here are some.

Triggers for Escalation in KYC:

1. Incomplete or Inaccurate Information: When the KYC documentation provided by the
client is incomplete or contains inaccuracies, it can trigger an escalation.
Solution: Request additional documentation or clarification from the client. Verify the
information provided through reliable sources. Ensure all required information is accurate and
up-to-date.
2. High-Risk Profile: If the client's background check or risk assessment reveals characteristics
associated with a high-risk profile, such as involvement in suspicious activities or adverse
media mentions.
Solution: Conduct enhanced due diligence (EDD) to gather more comprehensive information
about the client. Review their transaction history and assess the nature of their business or
activities to determine the level of risk accurately.
3. Sanctions or PEPs Matches: When a client's name or entity matches a sanctions list or
involves politically exposed persons (PEPs), it requires immediate attention.
Solution: Freeze the transaction, investigate further, and report the match to relevant
authorities if necessary. Enhanced due diligence may be required for PEPs.
4. Unusual Transaction Activity: Sudden or unusual transaction patterns, such as large and
unexplained transfers, may trigger suspicion of money laundering or fraud.
Solution: Investigate the transaction thoroughly, and if suspicions persist, consider filing a
Suspicious Activity Report (SAR) to the appropriate authorities.
5. Change in Customer Behaviour: Significant changes in a customer's behaviour, business
activities, or transaction patterns that deviate from their usual conduct may raise concerns.
Solution: Monitor the changes closely, conduct additional due diligence, and communicate
with the customer to understand the reasons behind the deviations.
6. Missing or Expired Documentation: If critical KYC documents, such as identification or
business licenses, are missing or have expired.
Solution: Promptly request the required documents from the customer and ensure compliance
with regulatory and internal policies.
7. Refusal to Provide Information: When a customer refuses to provide requested information
or is uncooperative during the KYC process.
Solution: Communicate with the customer to explain the necessity of the information and the
regulatory requirements. Consider further investigation if cooperation remains inadequate.
8. Complex Ownership Structures: Customers with intricate ownership structures or
affiliations that are challenging to trace and verify.
Solution: Conduct in-depth due diligence to unveil the true ownership and control structures
of the customer and assess associated risks.
9. Legal or Regulatory Changes: Changes in relevant laws or regulations that affect the KYC
process or customer risk assessments.
Solution: Stay informed about regulatory updates and adjust the KYC process as needed to
maintain compliance.
10. Internal Policy Violations: Instances where the customer's actions or behaviour violate the
organization's internal KYC policies and procedures.
Solution: Investigate the violation, communicate with the customer if necessary, and take
appropriate action based on internal policies.

Triggers for escalation in transaction payments as per document compliance

1. Lack of Quality and Quantity Inspection Certificates:
Trigger: Missing or incomplete quality and quantity inspection certificates for commodities.
Solution: Do not proceed with the transaction until these certificates are provided. Engage
relevant inspection agencies to conduct inspections when necessary.
2. Non-Compliance with International Trade Standards:
Trigger: Transactions that do not meet international trade standards or contractual
requirements for the specific commodity.
Solution: Review trade standards and contractual terms for each commodity. Ensure that
transactions comply with these standards and seek necessary approvals if deviations are
required.
3. Absence of Export or Import Licenses:
Trigger: Transactions involving commodities where export or import licenses are required,
but such licenses are missing.
Solution: Obtain the necessary export or import licenses before proceeding with the
transaction. Ensure that the licenses are valid and up to date.
4. Incomplete Shipping Documents:
Trigger: Transactions with incomplete or inaccurate shipping documents, such as bills of
lading or certificates of origin.
Solution: Require complete and accurate shipping documents from the parties involved.
Validate the authenticity of these documents.
5. Non-Compliance with Sanctions and Embargoes:
Trigger: Transactions that involve commodities from regions or entities subject to sanctions or
embargoes.
Solution: Ensure strict compliance with international sanctions and embargoes. Verify the
origin of commodities to prevent any breaches.
6. Failure to Meet Environmental or Safety Standards:
Trigger: Transactions involving commodities that do not meet environmental or safety
standards.
Solution: Assess whether the commodities comply with environmental and safety regulations.
Take corrective actions to address non-compliance or mitigate risks.
7. Payment Discrepancies and Financial Irregularities:
Trigger: Suspicion of payment discrepancies or financial irregularities related to commodity
transactions.
Solution: Investigate financial transactions thoroughly, including payment flows. Ensure that
all financial transactions adhere to internal financial controls and policies.
8. Legal or Regulatory Changes in the Commodities Market:
Trigger: Changes in legal or regulatory requirements affecting the trading of specific
commodities.
Solution: Stay informed about legal and regulatory updates for each commodity and adapt
trading practices accordingly.
9. Documentation Errors and Omissions:
Trigger: Errors or omissions in transaction documentation, contracts, or agreements.
Solution: Review documentation for accuracy and completeness. Correct any errors and
ensure that all parties involved have signed the necessary agreements.
10. Failure to Obtain Required Permits:
Trigger: Transactions involving commodities that require permits or approvals from relevant
authorities.
Solution: Obtain the required permits and approvals before proceeding with the transaction.
Ensure that all permits are in compliance with local regulations.