4.3 KiB
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.