2022 06 01 Ongoing client due diligence starting soon (Email notification from Saxo to wave one independent asset managers)

Dear partner,

As previously communicated, we are required to initiate a new ongoing due diligence (ODD) process and where applicable enhanced due diligence (EDD) on our clients before we migrate these clients to SaxoConnect. In the coming weeks, you can initiate ODD on your clients via our new client renewal module within SaxoConnect. We kindly ask for your collaboration to keep ensuring regulatory compliance for your firm and ours. 

Please validate and update your end-client information

The process covers the following steps:

1. Independent asset managers will need to review, validate and update client information currently registered with BinckBank/Saxo Bank.

2. The ODD review covers the following:

• Contact information
• Proof of residence
• Nationality
• Proof of identity - i.e., passport, national ID documented within the profile
• Industry and occupation, including current work status and title
• Politically exposed persons (PEP) self-declaration
• Financial information – salary after tax, investable assets, primary source of funds, source of wealth, intend to invest, proof of income or employment if elevated risks exist as documented within the profile
• Tax information – tax residency, tax ID and documentation which is documented within the profile

3. After validating and updating the information, Saxo will run the information through our automated risk models:

• Client ODD is performed digitally and clients with a fully verified identity profile, occupation, financials and background in line with their risk profile will experience an automatic ODD approval.
• Clients undergo manual handling when their information is inconsistent or when their inherent risks are high. As an example, when details such as financials, identity or residency are inconsistent, a KYC analyst will initiate feedback loops to obtain the required details through you before the ODD can be approved.

4. Enhanced Due Diligence (EDD) investigations will be conducted on clients considered high-risk:

• Risk areas triggered by the client include involvement in high-risk industries, PEP status, high level of AUM and similar.
• The EDD analysis uses public sources, proprietary screenings and we may request that you provide – or source from your client – the additional information or documentation required.
• Further, at Saxo, all high-risk clients require senior management approval to complete the ODD.

How do you review, validate and update your end-client information

We will use the client renewal module within SaxoConnect, which authorized employees will get access to.

As per the above, the full migration of your book of business to Saxo Bank is postponed until the client ODD process is well underway. While authorized employees will have access to SaxoConnect, securities and positions will remain in the Binck systems, and you should continue doing any trading exclusively from DBA.

Access to the client renewal module

We have already been in dialogue with many of you to specify the employee access to SaxoConnect. If you have not yet been contacted, it will happen soon.

Next, authorized employees will receive an email with login instructions. Each employee, as indicated to us, will receive an email from Saxo Bank with their user ID and will need to reset their password to access SaxoConnect. Only employees authorized for the role ‘client renewal’ will be able to access the module.

It is important to ensure that relevant staff have access to ‘client renewal’ in SaxoConnect. Should you need to revise authorization roles or add employees, please send an email to Christian Højberg at [e-mail].

How to use the client renewal module

You will see clients requiring ODD in the module under ‘Active renewals/New’. You can keep track of their status including clients waiting for Saxo to pick up, in progress on Saxo’s side, pending for you to submit additional information and processed indicating client has been renewed.

View our step-by-step guide for the client renewal module in our help centre.  

When will this take place

At the beginning of June, employees will receive emails with instructions to access SaxoConnect. 

Your firm should start the process of reviewing, validating and updating information by mid-June. It will be possible to start the process when you have access to SaxoConnect. On Saxo’s side, we will continuously process the information submitted and initiate feedback loops where required. It is important that you respond and help source the required information, allowing as many clients as possible to be finalized swiftly.

During June and July, we expect you to support us in finalizing the process by providing additional information and documentation as per the KYC queries.

Your support is essential. We are dependent on receiving all necessary client information from you in a timely matter to keep ensuring regulatory compliance for your firm and ours. 

Questions  

For questions regarding the ongoing due diligence process, do not reply to this email address but kindly contact the ODD team at [phone].

Questions regarding authorization roles and employee access rights to the client renewal module, please connect with Christian Højberg at [e-mail]. 

If you forgot your UserID or password to access SaxoConnect, take a look at the information in our help centre.  

If you have questions on how to use the client renewal module in SaxoConnect, please reach out to your regular account manager via incident tracking in DBA.

Best regards,

Saxo Bank