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AML Framework Review Active Client M Holdings

Section-by-section review of Client M's AML Framework against FATF Recommendation 10 and JYG's internal standard. Used for the upcoming 28 June refresh and any follow-up advisory work.

Project status On track
Combined from 3 updates · last update 2 hours ago by Andy Yu, via ChatGPT
Open questions
  • Client M to confirm who holds the MLRO role after October
Next steps
  • Lina to review Section 4.2 by Friday
  • Send revised draft to Client M by 20 June
Beneficial owner verification has had no update in 6 days. Work done in ChatGPT and not sent does not reach the project.

Finished work sent to this project, newest first. Each update was approved by the person who sent it.

AY
Drafted revised Section 4.2, parts 4.2.1 to 4.2.3
Andy Yu · 2 hours ago · via ChatGPT
On track

Rewrote the identification cascade, verification standards and source-of-funds wording for PEP-related ownership, using the three-tier risk model agreed on Monday.

DecisionsEnhanced due diligence applies from the medium tier upward.
Next stepsLina to review Section 4.2 by Friday.
LT
Agreed the three-tier risk model with Client M
Lina Tan · Monday, 11:05 · via Portal
At risk

Call with Client M's compliance officer. They accept low, medium and high tiers in place of the current two.

DecisionsUse a three-tier risk model.
Open questionsWho holds the MLRO role after October?
AY
Gap analysis against FATF Recommendation 10
Andy Yu · last week · via ChatGPT
At risk

Three material gaps on beneficial ownership: the 25% threshold cascade, the senior managing official fallback, and source of funds for PEP-related owners.

Every version is kept. A document sent again with the same name becomes its next version.

ClientM_AML_Section_4.2_Draft.docx
v2 · 2 versions · updated 2 hours ago by Andy Yu, via ChatGPT · scanned clean
ClientM_AML_Policy_v3.pdf
v1 · 28 pages · added by Lina Tan, via Portal · cited 7 times
Gap_Analysis_FATF_R10.xlsx
v1 · added last week by Andy Yu, via ChatGPT · scanned clean
JYG_Internal_AML_Standard.docx
v1 · 34 pages · added by Lina Tan, via Portal · cited 9 times

Everything that happened in this project: who, when, and from where. History is never edited or deleted.

    Key facts

    Everyone on the project

    Facts every chat should know, in ChatGPT and in the portal. Sent to ChatGPT whenever someone opens the project. Changes are recorded in History.

    • Client M's AML refresh deadline: 28 June 2026
    • JYG_Internal_AML_Standard.docx is the authoritative reference
    • Drafts should match Client M's existing tone (formal, sectioned)
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    Instructions for this project

    Every chat in this project starts with these, including ChatGPT when it opens the project through the connector.

    Your ChatGPT

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    Work in your own ChatGPT, then say "Send this to the project". You approve every update before it is saved here.

    1. JY Global connector added in ChatGPT (web)
    2. Signed in as Andy Yu
    3. 3Save the firm's standard instruction in ChatGPT
    Manage connection

    Members

    3

    Only members can open this project or send work to it, from ChatGPT or the portal.

    AY
    Andy Yu
    Owner · ChatGPT connected
    LT
    Lina Tan
    Member · ChatGPT connected
    JW
    James Wong
    Member · ChatGPT not connected
    Add member

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    • Section-numbered citations (FATF Rec. 10 §B style)
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    Documents

    4 files
    ClientM_AML_Section_4.2_Draft.docx
    v2 · 2 hours ago
    ClientM_AML_Policy_v3.pdf
    v1 · 28 pages
    Gap_Analysis_FATF_R10.xlsx
    v1 · last week
    JYG_Internal_AML_Standard.docx
    v1 · 34 pages