Information that needs examination
Adverse media means public reporting of potentially relevant negative information about a person or business. It can include allegations, investigations and court outcomes.
A report can give a reason for further customer due diligence (CDD). A headline alone does not establish identity, guilt or the required response.
Source: AUSTRAC: Collect additional KYC information; Verify or re-verify KYC information.
Separate the source from the claim
A useful review identifies who published the claim, the original evidence and the date. An article that repeats another report is not independent confirmation.
The review also distinguishes an allegation, a charge and a court finding. Later corrections, dismissals or appeal outcomes can change what the earlier report supports.
These are suggested evidence checks. The law requires risk-appropriate information and verification. It does not prescribe this exact research form.
Sources: AUSTRAC: Verify or re-verify KYC information; Federal Register of Legislation: Section 28(3).
- Source
Identify the publisher, original evidence and date.
- Status
Distinguish an allegation, a charge and a court finding.
- Later information
Examine corrections, dismissals and appeal outcomes.
Examine a report before using it
Suggested evidence checks. A headline alone does not establish identity, guilt or the required response.
Follow the process from top to bottom.
Connect the information to the customer
The business needs evidence that the report concerns the relevant person. A similar name may concern somebody else. The screening-match article gives that separate identity process.
A supported identity connection is only one step. The business then examines the conduct, its date and its relevance to the proposed service.
Source: AUSTRAC: Collect additional KYC information; Verify or re-verify KYC information.
A fictional report and a later correction
A fictional search finds an article that links a company director to a fraud investigation. A later correction states that the report named the wrong person.
The reviewer records both reports and the correction. The original headline no longer supports the same conclusion about the director.
If relevant concerns remain, the business examines its CDD and reporting duties. The suspicious matter report article gives the legal reporting test.
Sources: AUSTRAC: Verify or re-verify KYC information; Federal Register of Legislation: Section 41(1).