Review Workflow Patterns

A review workflow is a repeatable review pattern performed for a compliance team: client onboarding review, counterparty screening, supplier review, periodic review, EDD escalation or case-file preparation. The workflow should produce a review-ready case file, not only a narrative answer.

Review workflow model#

Review workflows covered#

These review patterns can be applied to:

WorkflowMain purposeTypical output
Client onboarding reviewUnderstand and verify a new customer before onboarding.CDD/KYC workpaper, evidence index, risk triggers and open questions.
Counterparty screeningReview a company, person or connected party before engagement.Screening summary, source checks and discrepancy register.
Supplier reviewCheck vendor or supplier exposure.KYB summary, sanctions/PEP/adverse-media references, risk notes.
Bank counterparty screeningReview financial-institution relationships.FI due diligence checklist and escalation memo if needed.
Employee screeningSupport controlled staff screening or rescreening workflows.Screening record and manual review triggers.
Periodic review / rescreeningRefresh old CDD/KYC/KYB information.Change log, refreshed source checks, updated risk factor mapping.
EDD / MLRO escalation supportPrepare complex or higher-risk cases for senior review.Escalation pack, evidence summary and unresolved questions.

Source-check workflow routing#

Each operation chooses source categories according to the subject and risk context. Examples include:

  • sanctions and targeted financial sanctions sources;
  • PEP sources;
  • adverse media sources;
  • official company and beneficial ownership registers;
  • commercial AML databases where the institution has valid access and a lawful basis for use;
  • domain, website, wallet or transaction intelligence sources where relevant;
  • internal documents, forms and prior case history.

This public reference describes source categories and evidence logic. Commercial database access, licences and credentials remain outside AML Bible.

Review-ready output#

A review workflow should be review-ready when another analyst can understand:

  • what was checked;
  • why those sources were used;
  • what identifiers were used;
  • what evidence supports each material fact;
  • where uncertainty remains;
  • what discrepancies exist;
  • which risk triggers are active;
  • whether the case should be escalated.

See Also#

References#