What is vetting?  

The purpose of vetting is to avoid hiring a person who may themselves pose an AML/CFT risk and  involves following a process that reviews an employee’s background. This includes checking:  

• They are who they say they are (verification of identification documents).  
• They are suitably qualified for the role they are undertaking (verification of qualification documents). 
• That they do not pose a ML/TF risk to your business (risk assessing, criminal history and associations). 
• Ensuring the information they have provided is correct (referee checks). 

How your business decides to vet its staff is a business decision. While it is ultimately your decision, simply completing a criminal history check will not give you assurance that your new employee does not increase your ML/TF risk.

To assist you further, you may wish to consider the following: 

• Differentiating your vetting processes for senior managers, compliance officers and customer facing roles. 
• How/if the process is varied when people change roles. 
• The vetting process for temporary staff. 
• Event triggered vetting (e.g., adverse media about a staff member, a suspicious activity report (SAR) is made in relation to an employee, or an employee fails to submit a SAR where one would have been expected). 

Vetting can sometimes be a difficult compliance area to manoeuvre – we are here to assist. If you have any questions or concerns, please do not hesitate to contact the friendly team here at Strategi.