Subjects: people and entities
The AML register holds subjects — natural persons and entities — each with a risk band and a status. Subjects arrive three ways: imported from Companies House officer lists, pulled from payroll employees, or added by hand; match suggestions catch the same person arriving twice.
Checks and match adjudication
Checks run against the screening provider (Sumsub) — identity, PEP and sanctions. Results come back as matches to adjudicate, not raw reports: you confirm or dismiss each candidate match, and the decision is recorded. Source-of-funds and origin facts live on the subject.
Ongoing monitoring
Screening doesn’t stop at onboarding: monitoring alerts arrive from the provider (signed webhooks) when a subject’s status changes, and land in the register for review.
Risk bands
Each subject carries a band — low / medium / high — set by your judgement on the evidence. The band drives attention, not automation: a high-band subject is a standing question, not a blocked record.
The audit log
Every check, adjudication and band change lands in the AML audit log — the trail your supervisor’s inspection will ask for.