Step by step
Identify a client
Record a client's identification, check the documents, screen the client against the sanctions lists and verify them, as the firm's due diligence requires.
Identification is one of the three things an enquiry must pass before it becomes a matter, with the conflict search and the engagement. You record who the client is and where the money comes from; Kila then opens a due diligence case with the documents to see and the screening to record, and keeps the evidence.
Open the client's identification
Go to Practice › Clients, open the client and tap the KYC and conflicts tab. Under Identification and due diligence, tap Open. A new client is Not identified and their identification is Not recorded yet.
Record the identification
Choose what The client is, then fill in the ID type and ID or passport number (for a company, the Registration number and its beneficial owners), the KRA PIN and the Address. Tick Politically exposed (or family or a close associate of one) when it applies. Say where the money comes from under Source of funds (for this matter) and Source of wealth. Tap Save the identification.
Open the case
Kila says Saved. and opens an onboarding case for the client. Tap Open case KYC-…. Under Before it can be verified, the case lists what is left, such as “Screen the client against the sanctions lists.”
Check each document
The list is “For Individual clients (the firm sets the list)”: for example National ID or passport (certified copy), KRA PIN certificate and Proof of address (utility bill, lease or letter from the chief). Tap Verified once you have seen the original (Kila notes “Original seen at the office.”) or attach the copy. For one the client does not need, tap Not needed and answer “Why is it not needed?”.
Record the screening
Search the lists on their official pages, then tap Record a screening: fill in Who was screened, As, the Result and Checked on, and give the Search reference or attach The printout. Tick the Lists searched and tap Record. Kila says Recorded.
Check the risk
Risk adds up points for each factor that applies, such as Not met in person or High-value property or company transaction: “Medium from 25, high from 50”. Tick the factors you judge; those marked From the file follow the client’s record.
Tap Verify
The button works once nothing is left. Kila says when the next review is due, such as Verified. Review by 2029-10-30., and the case shows Verified, with who Decided and when.
The law says
The case names what it rests on: “Proceeds of Crime and Anti-Money Laundering Act (POCAMLA), as amended by the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act, 2023, which made advocates reporting institutions for specified transactions; POCAML Regulations. Verify with the firm.” The screening card adds: “The UN, US, UK and EU lists and the Kenyan list under the Prevention of Terrorism Act are searched by hand on their official pages; keep the printout or the reference.”
Good to know
The demo firm’s screening dialog also has Test mode, which answers from made-up names. A live Kila refuses it: “The screening test mode is for the demo site and development only. Record the screening by hand.” Kila is not connected to a screening provider, so search the lists yourself and record the screening by hand, as above.
The client needs enhanced due diligence
Link to this section: The client needs enhanced due diligenceA politically exposed or high-risk client’s case has an Enhanced due diligence card for “The checks made and the evidence seen (asset declarations, bank letters, searches).” Instead of being verified, it goes to a partner and shows Waiting for a partner:
Verify stays grey
Link to this section: Verify stays greyRead Before it can be verified at the top of the case: each line is something still to do, such as a document not yet verified or the screening.
The firm will not act
Link to this section: The firm will not actTap Reject and say why. Kila explains: “The enquiry closes as declined; a suspicion goes to the reporting officer separately (never tell the client: tipping off is an offence).”
Needs a manager
Recording and verifying identification needs the right to manage it, which the receptionist, the advocates, the partners and the compliance officer have at Wanjiru & Otieno Advocates. Enhanced due diligence is approved by a partner who did not prepare it.
- Run a conflict search: the other check before the matter opens.
- Compliance officer (AML): due diligence, AML cases and the registers.
Next: with the search cleared and the client identified, open the matter: Open a matter.