Understanding Mitigation Templates
What are Mitigation Templates?
Mitigation Templates provide your team with standardized, step-by-step instructions for addressing specific risks identified during customer assessments. When a rule is triggered, the associated mitigation template guides your team through the required compliance actions.
Why are Mitigation Templates Important?
Consistency: Ensures all team members follow the same procedures
Compliance: Documents that regulatory requirements are being met
Efficiency: Provides clear instructions, reducing time spent determining next steps
Audit Trail: Creates standardized documentation for regulatory reviews
Mitigation Templates should be created before you configure rules, as rules reference these templates. Think of templates as the "how-to" guide that rules point to when risks are identified.
How Templates and Rules Work Together
The relationship between rules and mitigation templates creates your automated risk assessment workflow:
Rule is Triggered: A customer's attributes (jurisdiction, entity type, PEP match, etc.) trigger a specific rule
Risk Identified: The rule identifies the inherent risk level
Template Applied: The linked mitigation template provides instructions for addressing the risk
Actions Completed: Your team follows the template's steps and documents their actions
Risk Reduced: The inherent risk is reduced to the target residual risk level
Scenario: An investor from a high-risk jurisdiction applies to invest in your fund
Rule Triggered: "High-Risk Jurisdiction Investor" rule activates
Inherent Risk: High
Mitigation Template: "Enhanced Due Diligence - High-Risk Jurisdiction"
Actions Required: Template instructs team to obtain additional documentation, verify source of funds, conduct adverse media checks
Outcome Documented: Team records all actions taken in the platform
Residual Risk: Medium (or as defined by your risk appetite)
Accessing the Configuration Area
Step 1: Navigate to Configuration
Log into the VerifiMe Management Portal using your credentials
From the left-hand navigation menu, select Configuration
You'll see two tabs: Rules and Mitigation Templates
Each tab displays your existing configurations. You can click on any item to view full details, edit, or delete.
Creating Mitigation Templates
Step 1: Access Mitigation Templates
Navigate to the Mitigation Templates tab
Click + Add Mitigation (or similar button)
Step 2: Complete Template Fields
You'll need to complete the following fields:
Title
Provide a clear, descriptive name that identifies the mitigation action
Use consistent naming conventions across your templates
Examples: "Enhanced Due Diligence - Standard PEP", "Source of Wealth Verification - High Value"
Details
This is the most important section - it should contain comprehensive information including:
Background on the Regulatory Requirement
Which regulation or policy this mitigation addresses
Why this mitigation is necessary
The objective of completing these steps
Step-by-Step Instructions
Clear, numbered steps for your team to follow
Specific actions required at each step
Any system processes or external tools to be used
Required Documentation or Evidence
List of documents that must be obtained
Acceptable forms of evidence
Where documents should be stored
Completion Criteria
What constitutes successful completion
Quality standards to be met
When the mitigation can be marked as complete
Step 3: Write Effective Template Content
Use Clear, Actionable Language
Write as if instructing someone unfamiliar with the process
Avoid jargon or assumptions about prior knowledge
Use active voice: "Obtain certified copies..." rather than "Copies should be obtained..."
Be Specific About Documentation
State exactly which documents are required
Specify certification requirements (e.g., "certified within the last 3 months")
Indicate acceptable alternatives if primary documents are unavailable
Include Regulatory References
Cite relevant AML/CTF regulations or internal policies
Link to regulatory guidance where applicable
Note any jurisdiction-specific requirements
Define Success Criteria
Clearly state what "complete" looks like
Specify any approval requirements
Note any time limits or deadlines {panel}
Example Template Content
Title: Enhanced Due Diligence - PEP Match
Details:
Background: This mitigation is required under Section 18 of the AML/CTF Act when a customer is identified as a Politically Exposed Person (PEP). Enhanced due diligence ensures we understand the source of wealth and monitor for potential corruption or bribery risks.
Step-by-Step Instructions:
Verify PEP Status
Confirm the PEP match details in the screening report
Determine if the person is a current or former PEP
Identify their specific role and jurisdiction
Obtain Enhanced Documentation
Obtain proof of residential address dated within the last 3 months
Request a statutory declaration regarding source of wealth
Obtain supporting evidence of source of wealth (e.g., business sale documents, employment contracts, inheritance documentation)
Source of Wealth Verification
Review all source of wealth documentation
Verify legitimacy through independent sources where possible
Assess consistency between declared wealth and known income sources
Adverse Media Search
Conduct comprehensive adverse media search using [specified platform]
Search for allegations of corruption, bribery, or financial crime
Document search results and any findings
Senior Management Review
Prepare summary of findings for compliance manager review
Obtain written approval to proceed or escalate concerns
Document approval with date and approver name
Required Documentation:
Utility bill or bank statement (dated within 3 months)
Statutory declaration - source of wealth
Supporting source of wealth evidence
Adverse media search report
Senior management approval email/memo
Completion Criteria:
All documentation obtained and verified
No unresolved adverse media findings (or adequately explained)
Senior management approval obtained
All findings documented in customer file
Residual risk assessment confirms Medium or Low risk level
Step 4: Save and Review
Click Save Template
The template will appear in your Mitigation Templates list
Click into the saved template to verify all details are correct
Test the template by reviewing it from a team member's perspective - is it clear and actionable?
Linking Templates to Rules
Once your mitigation templates are created, you'll link them to rules during the rule configuration process.
When Configuring a Rule
Navigate to Configuration > Rules
Create a new rule or edit an existing rule
Under the Mitigation Templates section, click + Add Template
Search for and select the relevant mitigation template(s)
Note: the format of the search criteria must match the template exactly inclusive of upper and lower case characters.
Multiple templates can be linked to a single rule - this allows you to provide different mitigation options based on specific circumstances
Why link multiple templates?
You might link several mitigation templates to a single rule to provide flexibility based on specific customer circumstances:
Example - PEP Match Rule might include:
Template 1: Enhanced Due Diligence - Domestic PEP
Template 2: Enhanced Due Diligence - Foreign PEP (High-Risk Jurisdiction)
Template 3: Enhanced Due Diligence - Family Member of PEP
Template 4: Senior Management Approval Required
Your team can then select the most appropriate template when completing the mitigation based on the specific PEP match details.
Ensuring Template-Rule Alignment
When linking templates to rules, verify that:
Templates address the specific risk identified by the rule
Completion of the template will reduce the inherent risk to the target residual risk level
Required actions are proportionate to the risk level
Documentation requirements meet your regulatory obligations
Using Templates When Rules are Triggered
When a customer assessment triggers a rule, your team will use the linked mitigation template to address the identified risk.
Step 1: Review Triggered Rule
When you receive a notification or review a customer assessment, you'll see which rules have been triggered.
Step 2: Select Mitigation Template
Click into the triggered rule
Review the available mitigation template(s)
If multiple templates are available, select the most appropriate one for the specific circumstances
4. Click to open the template and view the full instructions
Step 3: Follow Template Instructions
Work through the template's step-by-step instructions systematically
Obtain all required documentation
Complete all verification steps
Conduct any required searches or checks
Obtain necessary approvals
Work through templates in order - each step often builds on the previous one. Skipping steps may result in incomplete due diligence.
Step 4: Document Your Actions
As you complete the mitigation, document your actions in the platform's documentation field:
Date each action
Record what was done at each step
Note evidence obtained and where it's stored
Document findings from searches or reviews
Record approvals with approver names and dates
State the outcome and final risk assessment
Step 5: Complete the Mitigation
Verify all template steps have been completed
Ensure all documentation requirements have been met
Confirm the residual risk level has been achieved
Save the completed mitigation in the platform
Managing Existing Templates
Editing Mitigation Templates
As regulations change or your processes improve, you may need to update your templates:
Navigate to Configuration > Mitigation Templates
Click on the template you wish to modify
Select Edit to make changes
Update the relevant fields (Title, Details, etc.)
Click Save Template
Important: Changes to templates will apply to all rules that reference them. Ensure any updates maintain consistency with your linked rules and risk frameworks.
Deleting Mitigation Templates
Critical Warning Deleting templates that are linked to active rules may impact your compliance workflows. Before deleting a template:
Check which rules reference the template
Deactivate those rules first, or
Link alternative templates to the rules
Only then delete the unused template
To delete a template:
Navigate to Configuration > Mitigation Templates
Click on the template you wish to remove
Verify it's not linked to any active rules
Select Delete
Confirm the deletion
Support and Assistance
Need Help with Template Configuration?
For technical assistance:
Contact VerifiMe support through the Management Portal help section
Email: [email protected]
Include screenshots of any errors or issues
For compliance guidance:
Consult with your internal compliance team
Reference your AML/CTF Program requirements
Review relevant regulatory guidance documents
Consider engaging external compliance advisors for complex scenarios
Related Documentation
Client Instruction Guide: Configuring Rules on VerifiMe
Client Guide: Mitigating Identified Risks in VerifiMe
Client Guide: Setting Up Email Notifications and User Access