Join us as we delve deep into how compliance teams should approach the heady world of High Net Worth Individuals (HNWI) and anti-money laundering (AML).

You can read Part 1: Follow the money here.

Part 2: Time poor and anxious.

It’s said that time is money, and when dealing with HNWIs it should be amended to include ‘and everyone wants some’. This group is used to getting what they want when they want it. If they don’t, they understand that plenty of others will bend over backwards to get their business. 

So how is a compliance team best to work with them? You need to get the relevant information to minimise corporate risk but you cannot upset them or you risk costing your company a lucrative client, and a valuable revenue stream. 

Having worked closely with hundreds of HNWIs across the globe, there are three key areas to focus on.

What’s their business?

As said, HNWIs are time-poor, so they expect you to come to them knowing exactly what you need and how it relates to their business.

Did they make their money mining crypto? You better know to ask for electricity or server bills to prove they actually mined it, their local bank statement to prove where it was cashed in, and you better know that the exchange they cashed it out on is reputable. Well-known doesn’t make it reputable! 

Whatever you do, don’t go in asking for a simple bank or portfolio statements. Get to the point, really understand their business so you can ask smart questions and more importantly, ask for relevant documentation.

Whatever you do, don’t go in asking for a simple bank or portfolio statements. Get to the point, really understand their business so you can ask smart questions and more importantly, ask for relevant documentation.

Privacy is paramount.

HNWIs guard their privacy fiercely and expect security that’s second to none. A lot of the time, the information a compliance team asks for is highly sensitive; whether it be commercially or personally. 

For example, consider a real estate transaction. The HNWI will be concerned if other agents can see their level of wealth or how many other property transactions they’ve made. Their fear is that they will be targeted or harassed to spend more or buy additional properties.

If the HNWI is a business owner, they’ll be additionally concerned that their commercial information can be sold to competitors or used for extortion. 

They are incredibly aware that their information could be leaked to the news or exposed for nefarious reasons. 

So, every single time you deal with an HNWI, preface the conversation with:

• where the information is going 
• who will have access
• how it’s being stored
• how long it’s going to be held on file

Packs. They’re not always as advertised.

Finally, unless your company uses First AML and has access to the global complex entity ecosystem, which HNWIs are part of, you’ll be asking for the same information as everyone else.

HNWIs are busy so usually have AML packs ready to go. But, as a compliance professional, you can’t just take these at face value. Take the time to read the pack and make sure you're understanding what’s in it.

Each company has its own accepted level of risk. Just because other compliance officers have said the HNWI is ok, it doesn’t automatically mean the same for you. Depending on the product or service you’re selling, what location you’re in and also the time period you’re engaging; things change very quickly with HNWIs, so read and understand the provided information.

So in summary, when dealing with HNWIs, be discreet, make it easy, get to the point and ask smart questions.

Want to read more? Check out the other parts of the series here!

Part 1: Follow the money

Part 3: Family ties and alibis

Part 4: Crypto, NFTs, gems