Financial crime cold start interview

Financial Crime / AML Cold-Start Interview

Purpose

Conduct a structured, staged interview with a financial-crime practice group — led by a supervising attorney or authorized designee — to gather the information required to populate practice-profiles/financial-crime.md. The skill walks through all eight profile fields in sequence, records every answer, and assembles a filled draft of the profile for the practice group's review and approval. It produces draft legal work product for attorney review — not legal advice and not a final configuration.

Use When

• A team is adopting AgentCounsel and needs to configure practice-profiles/financial-crime.md for the first time.
• A financial-crime practice group is being onboarded to the library and no current profile exists.
• The library is being stood up for the first time and the financial-crime area is included in scope.
• A practice group wishes to revisit or rebuild its profile from scratch rather than make incremental updates.

Required Inputs

• A knowledgeable person from the financial-crime practice group — a supervising attorney or an authorized designee — who can answer questions about the group's jurisdiction, positions, escalation rules, and review requirements.
• Any existing playbooks, templates, source-of-truth documents, or standard-form documents the group already uses, so they can be referenced or cited in the profile.

Do Not Use When

• The group is actively working a live financial-crime matter. This skill configures the library; it does not support an open matter.
• A practice-profiles/financial-crime.md already exists and is current. In that case this is a refresh, not a cold start — though the skill may still be used to rebuild the profile deliberately.
• No authorized person is available to answer. Do not complete the interview with guessed or inferred answers; record all gaps as [CONFIRM: ...] placeholders.
• The purpose is to handle a specific financial-crime matter (use the appropriate matter-level skill for that task).

Legal Safety Rules

• Produce draft legal work product for attorney review. This is not legal advice.
• Never guess or infer an answer to any interview question. If the interviewee cannot answer a question, record [CONFIRM: answer required from practice group] and move on.
• The filled profile is a draft. It must be reviewed and explicitly approved by the supervising attorney or practice group before it governs any AgentCounsel work product.
• Do not invent standard positions, clause preferences, escalation thresholds, or review rules. Record only what the interviewee provides.
• Do not include client-specific facts, client names, matter identifiers, or privileged details in the profile. The profile is a reusable group-level configuration, not a matter record.
• Do not state or imply that any threshold, position, or rule in the profile satisfies a legal requirement under any jurisdiction. Jurisdiction-specific legal obligations are for the attorney to verify.
• Flag every item the interviewee defers or leaves open with a visible [CONFIRM: ...] placeholder so the reviewer can see exactly what is unresolved.

Workflow

Stage 1 — Jurisdictions

Ask the interviewee:

• In which jurisdictions does the group support KYC, customer due diligence, and sanctions / PEP / adverse-media screening work most frequently?
• Which regulated entities does the group work with, and which supervisory regimes govern their AML programs?
• Are there jurisdictions, list sources, or sanctions regimes the group treats as in scope for screening, and how is that coverage tracked?
• Are there cross-border relationships — foreign UBOs, offshore structures, non-resident applicants — that the group routinely encounters and must account for?
• Are there jurisdictions or sanctions regimes the group treats as out of scope entirely, requiring escalation or specialist outside counsel?

Record answers. Mark any unanswered item [CONFIRM: jurisdiction not yet specified].

Stage 2 — Client and Team Context

Ask the interviewee:

• Does the group support primarily a financial institution's compliance function, a corporate client's onboarding team, outside counsel, or a mix? Confirm the default posture.
• What types of financial-crime matters does the group handle most frequently — onboarding KYC, periodic refresh, beneficial-ownership analysis, sanctions / PEP / adverse-media alert adjudication, or others?
• How is the team structured — compliance officers, onboarding analysts, supervising attorneys, paralegals, non-attorney professionals whose work must be supervised?
• Are there applicant categories — high-risk customers, PEPs, complex ownership structures, correspondent relationships — that require enhanced due diligence or additional sign-off?
• How does the group coordinate with the firm's compliance function, MLRO or BSA officer, and any external screening providers?

Record answers. Mark any unanswered item [CONFIRM: client/team context not yet specified].

Stage 3 — Escalation Thresholds

Ask the interviewee:

• Which KYC findings automatically require escalation — opaque or undisclosed beneficial ownership, missing source-of-funds evidence, expired or unverifiable identity documents, high-risk-jurisdiction exposure?
• Which screening outcomes require mandatory escalation — a possible or likely true sanctions match, a confirmed PEP designation, significant adverse media — regardless of the screening context?
• Is there a customer risk-rating outcome (for example, a high rating, or a recommendation to decline or apply enhanced due diligence) that always triggers escalation, and to whom?
• What is the escalation path when a suspicious-activity concern or potential reporting obligation surfaces during a review?
• Who is the designated escalation contact for financial-crime matters — the MLRO, BSA officer, or supervising attorney — and what is the expected turnaround?

Record answers. Mark any unanswered item [CONFIRM: escalation threshold not yet specified].

Stage 4 — Preferred Output Style

Ask the interviewee:

• Should financial-crime work product default to a structured KYC onboarding file, a screening / alert-adjudication review, a compliance-facing summary, or several layered?
• What format does the group use for the customer risk rating and disposition recommendation — factor table, narrative, or both?
• Are there house style rules for confidence classifications, risk ratings, escalation flags, or open questions in financial-crime work product?
• Does the group produce document-inventory tables, beneficial-ownership charts, or alert-disposition tables, and if so, in what format?
• Are there particular deliverable types — onboarding files, screening reviews, escalation packets — for which the group has mandatory format requirements?

Record answers. Mark any unanswered item [CONFIRM: output style preference not yet specified].

Stage 5 — Source-of-Truth Documents

Ask the interviewee:

• What is the group's authoritative KYC/AML rules grid or CDD policy, including the required-document matrix and risk-rating methodology, and where is it stored?
• Is there a separately maintained high-risk-jurisdiction list, and how is it kept current?
• What document governs the group's screening or alert-disposition policy, including match thresholds and false-positive criteria?
• Does the group maintain a beneficial-ownership / control verification standard, and is it tied to specific applicant types?
• Are there enhanced-due-diligence procedures or escalation playbooks the group treats as authoritative, and is any of them under revision or pending update?

Record answers and document names. Mark any unanswered item [CONFIRM: source document not yet identified].

Stage 6 — Standard Positions and Playbooks

Ask the interviewee:

• What is the group's default customer due diligence posture by applicant type, and what triggers a step up to enhanced due diligence?
• What is the group's default beneficial-ownership threshold and control standard for identifying UBOs and controllers?
• What is the group's default source-of-funds / source-of-wealth evidence expectation across risk levels?
• What is the group's default approach to disposition recommendations — clear, request documents, escalate to enhanced due diligence, or recommend decline — and what drives each?
• What is the group's default posture on screening: which list sources are screened, how possible matches are handled, and how false positives are documented?

Record answers. Mark any unanswered item [CONFIRM: standard position not yet specified].

Stage 7 — Attorney Review Requirements

Ask the interviewee:

• At what stage of a financial-crime matter does attorney or compliance review of work product become mandatory — intake, before any risk rating, before any disposition recommendation, before any escalation, or at other defined stages?
• Are there work-product types for which review is always required regardless of matter size — for example, any sanctions match, any high-risk rating, any recommendation to decline, any enhanced-due-diligence file?
• What is the designated reviewer's role — handling attorney, supervising attorney, MLRO or BSA officer, compliance lead?
• What is the expected turnaround for standard onboarding or screening review, and how are urgent reviews (potential sanctions exposure, time-sensitive onboarding) handled?
• Is there a formal sign-off step — required signature, approval, or logged confirmation — before a customer is onboarded, an alert is dispositioned, or an escalation packet is transmitted?

Record answers. Mark any unanswered item [CONFIRM: review requirement not yet specified].

Stage 8 — Prohibited Assumptions

Ask the interviewee:

• Are there facts, postures, or conclusions agents must never assume without explicit confirmation — that an applicant is cleared, that a risk rating is low, that beneficial ownership is complete, that a screening alert is a false positive, that source of funds is adequately evidenced?
• Are there scenarios — a possible sanctions match, a confirmed PEP, a suspicious-activity concern — where an agent must stop and escalate rather than reason through independently?
• Are there matter types or applicant populations (high-risk customers, complex ownership structures, correspondent relationships) where agents must never proceed beyond intake without direct compliance or attorney involvement?
• Are there prior incidents, regulator findings, or lessons learned that should be encoded as explicit prohibitions for agents working on financial-crime matters?

Record answers. Mark any unanswered item [CONFIRM: prohibited assumption not yet specified].

Stage 9 — Assemble the Draft Profile

Compile all answers into a filled draft of practice-profiles/financial-crime.md, populating each of the eight profile sections. For every item that was not answered, insert a visible [CONFIRM: ...] placeholder with enough context for the reviewer to understand what needs to be supplied. Append a list of all open placeholders so the reviewing attorney can see at a glance what remains unresolved.

Output Format

Deliver:

1. Filled draft of practice-profiles/financial-crime.md — all eight sections populated with answers from the interview. Every unanswered item is a visible [CONFIRM: ...] placeholder.
2. Open-items list — an explicit enumeration of every placeholder inserted, with the stage and question it corresponds to, so the reviewing attorney can resolve them efficiently.

Label the entire output: Draft legal work product for attorney review. Not legal advice. This profile draft must be reviewed and approved by the supervising attorney or practice group before it is relied upon.

Attorney Verification Checklist

• All eight profile sections have been reviewed by a supervising attorney or authorized practice-group representative.
• Jurisdiction and sanctions-regime coverage for KYC and screening work is accurately recorded [verify jurisdiction].
• KYC/AML rules grid, CDD policy, and high-risk-jurisdiction list references are current and version-controlled [Verify current law].
• Beneficial-ownership thresholds and the customer risk-rating methodology reflect the group's current considered posture, not a provisional one.
• Screening / alert-disposition thresholds and false-positive criteria reflect the firm's current policy, and every possible or likely true sanctions match is routed to compliance and counsel.
• Any reporting, response, or refresh dates surfaced during a review are marked [deadline verification required] and are computed by the attorney or compliance function, not by an agent.
• No client-specific facts, matter identifiers, or privileged details appear in the profile.
• All [CONFIRM: ...] placeholders have been resolved or explicitly accepted as pending.
• The approved profile has been saved to practice-profiles/financial-crime.md and its effective date recorded.
• A process for periodic profile review and update has been identified.