Files
random_corp/financial_crime/entities/person.md
T

4.3 KiB

Financial Crime

Entities

Person

A Person is a natural person who has, or may have, a financial relationship with the institution. Person specialises Party, inheriting all universal party attributes and adding those that are specific to a natural person — including identity verification details, biographic attributes, and PEP status.

Under the AUSTRAC AML/CTF Act 2006 and RBNZ AML/CFT Act 2009, the identification and verification requirements for individuals differ materially from those for legal entities, making Person a distinct and necessary specialisation.

---
config:
  layout: elk
---
classDiagram
  class Party{
    <<abstract>>
  }

  class Person{
    Date of Birth : date
    Country of Birth : string
    Nationality : string[]
    Country of Residence : string
    Politically Exposed Person Status : enum~PEPStatus~
  }

  Person --|> Party

  class PEPStatus["<a href='https://github.com/Semprini/md-ddl/blob/main/examples/Financial%20Crime/enums.md#pep-status'>PEP Status</a>"]{<<enumeration>>}
  
  class Party["<a href='https://github.com/Semprini/md-ddl/blob/main/examples/Financial%20Crime/entities/party.md'>Party</a>"]  
extends: Party
existence: independent
mutability: slowly_changing
attributes:
  Date of Birth:
    type: date
    pii: true
    description: >
      The individual's date of birth as recorded on their primary identity document. Required for identity verification under the AML/CTF Act 2006 Part B customer identification program.

  Country of Birth:
    type: string
    pii: true
    description: >
      The country in which the individual was born. Used as a supplementary identity verification attribute and as an input to jurisdiction risk scoring.

  Nationality:
    type: string[1..*]
    pii: true
    description: >
      One or more nationalities held by the individual. A key factor in sanctions jurisdiction screening — an individual may hold nationality in a sanctioned country while residing elsewhere.

  Country of Residence:
    type: string
    pii: true
    description: >
      The country in which the individual currently resides. Used for jurisdiction risk scoring, FATF high-risk country screening, and determining applicable CDD obligations.

  Politically Exposed Person Status:
    type: enum:PEP Status
    description: >
      Indicates whether the individual is a Politically Exposed Person, a close associate of a PEP, or a family member of a PEP. PEP status applies only to natural persons. Triggers mandatory Enhanced Customer Due Diligence under the AML/CTF Act 2006 and RBNZ AML/CFT Act 2009 section 22.
constraints:
  Date of Birth Required at Onboarding:
    not_null: Date of Birth
    lifecycle_stage: Onboarding
    description: >
      Date of birth is a mandatory identification attribute for individuals under the AML/CTF Act 2006 Part B customer identification obligations. It must be collected and verified before any designated service is provided.

  PEP Requires High Risk Rating:
    check: >
      Politically Exposed Person Status == 'Not PEP'
      OR Risk Rating IN ('High', 'Very High')
    description: >
      Any individual identified as a PEP or PEP associate must be assigned a
      minimum Risk Rating of High, inherited from Party. This triggers
      Enhanced Customer Due Diligence obligations under the AML/CTF Act 2006
      and RBNZ AML/CFT Act 2009. The Risk Rating constraint is evaluated
      against the inherited attribute.
governance:
  pii: true
  classification: Highly Confidential
  retention: 10 years
  retention_basis: Domain default retention aligned to AML/CTF record-keeping obligations
  description: >
    10-year retention from the end of the business relationship, aligned to
    AUSTRAC and RBNZ record-keeping obligations. The regulatory minimum is 7
    years under AUSTRAC AML/CTF Act 2006; the domain default of 10 years is
    applied as the conservative standard.
  access_role:
    - FINANCIAL_CRIME_ANALYST
    - KYC_OFFICER
    - COMPLIANCE_OFFICER
  compliance_relevance:
    - AUSTRAC AML/CTF Act 2006 — Part B Individual Identification
    - AUSTRAC AML/CTF Amendment Act 2024
    - RBNZ AML/CFT Act 2009 — sections 14, 22
    - FATF Recommendation 12 — Politically Exposed Persons

Relationships

No relationships are sourced directly from Person in the current domain model.