COMMA CHECK-IN - Check Lists · Manuale Operativo Comma Check-In 11 3 Batch Comparison (Matching)...

Manuale Operativo Comma Check-In 1

COMMA CHECK-IN

Operational Handbook Version 11th


SUMMARY

1 INTRODUCTION ................................................................................................................................ 3

2 MANUAL CHECK-IN COMPARISON .................................................................................................. 4

2.1 Enquiry Criteria ................................................................................................................................................... 4

2.2 Results Meaning .................................................................................................................................................. 5 2.2.1 Duplicated Research .............................................................................................................................................. 6 2.2.2 Research with Negative Outcomes ........................................................................................................................ 7 2.2.3 Research ended in Error ........................................................................................................................................ 7

2.3 Protocol Printing ................................................................................................................................................. 8

3 BATCH COMPARISON (MATCHING) ............................................................................................... 11

4 OUTCOME REPORTS AND DETAILED TABLES ................................................................................ 12

4.1 Reading a Protocol ............................................................................................................................................ 12

4.2 Outcome Reports .............................................................................................................................................. 17

4.3 Report Details ................................................................................................................................................... 21

5 CASE MANAGEMENT ...................................................................................................................... 23

5.1 Results Evaluation ............................................................................................................................................. 23 5.1.1 Subjects Revaluations .......................................................................................................................................... 25

5.2 Other Options in Case Management Menu ....................................................................................................... 26 5.2.1 Attachments ........................................................................................................................................................ 26 5.2.2 Events .................................................................................................................................................................. 27 5.2.3 Notes .................................................................................................................................................................... 28

5.3 Protocol Management and Archiving ................................................................................................................ 28

5.4 Protocol Cancellation ........................................................................................................................................ 31

6 RESEARCH ....................................................................................................................................... 33


1 Introduction

Comma Check-in is a module being part of Comma 3D Suite. It is dedicated to the legal

enforcement of the 231/07 act, issued in the Italian laws. It implements the surveillance lists

and the names directory to be verified, provided from batch processing (Matching), from

manual input and from any other external application.

The original list data (UIF, EU, UNISC, OFAC, PEP, PIL) is transmitted through an automatic

batch, processed and finally uploaded to the predefined database.

Periodic updates (new insertions, deletions, changes) are included in the existing lists. The

comparison takes place though the unique identifier of the list and the unique identifier of

the Subject.

The Check-In system can operate in two modes:

1. the Manual Verification

2. the Massive Verification

In the Manual Verification each User, duly profiled to access to the system, insert the

Subject to be investigated in the “Manual Check-In”section, and can select the accuracy

level of the research (low, middle, high) and the Lists on which perform the query.

In the Massive Verification, the system check automatically the Names listed in the

Customer and Supplier records sent by each Company that makes use of this service, and

analyse the accuracy with the Lists, sufficed to preset values of goodness and range.


2 Manual Check-In Comparison

To verify when a Customer or a Provider is listed in a surveillance blacklist, the user can

access to the Manual Check-in section.

The research could be performed by:

▪ Natural person;

▪ Legal person.

The mandatory key fields for the enquiry are Name and Surname in case of natural person

and Company name in case of legal person.

2.1 Enquiry Criteria

Once the data of the Customer or the provider have been inserted, the user must select the

lists on which he wants to perform the research (all the lists or only those of interest).


Then the user set up the precision criteria of the phonetic research:

For a correct extraction, it is recommended to set the value Media/Middle.

As result, a list of denominations is extracted, all these denominations are phonetically

similar to the one typed in input. The threshold indicates that the similarity between the

customer name and the names found in the query is equal or higher than this precision

criteria.

As low is the requested precision as wide will be the set of extrapolated denominations

phonetically similar to the sought customer name.

2.2 Results Meaning

As first example, let suppose we must check a customer having Ahmed as surname, with

“middle“ accuracy in all the available lists. Then the user must choose Natural Person as

person type and fill the field Surname with Ahmed as shown in the screen below:

As result, a list of subjects will be extracted. The subjects are reported in the various lists,

with the indication of the total number found (in this case 100 subjects are found in the

UIF/UE/UNSC/FAC list and 0 in the other lists).


As it can be seen in the latter image, the information listed are: Status, Person ID, Person

Denomination, Person type and Accuracy.

As second example, let suppose we must check a Company named Ocean Limited.

In this case, the Person Type to be chosen is: Legal Person. Then the Company Name field

must be filled with the searched name, and the Search Criteria and the Available Lists must

be set (see the following screen).

About the latter, please remember to clear the lists related to Natural Person (PEP e PIL)

when a Legal Person is verified.

According to the search criteria settings, the legal entity extrapolated by the query will be listed in the protocol management screen, as seen in the Natural Person query.

2.2.1 Duplicated Research

In case of a query that involves a Customer, who was already inquired on the same day, a

warning screen notifies the user that a duplicate search is taking place:


Clicking on Yes, the query will be repeated.

2.2.2 Research with Negative Outcomes

It is possible that a research ends in an empty result, e.g. when performed with Exactly or

High accuracy values (it should be noted, however, that the standard the recommended

precision level is the Middle). In this case, the following “no results found” warning screen

will appear:

Clicking on No button, the user will definitively end the search. Instead, clicking on Yes

button, the user will resume it: the search can be repeated only with lower accuracy values

(as Middle or Low). The Print no match button creates a pdf file, that reports only the “no

match” result.

2.2.3 Research ended in Error

The search may also end up in error, e.g. due to web services connection troubles. In this

case the following warning message will appear:


The user may decide not to store the research, clicking on Yes button (then consider it as

never happened), or may instead decide to historicize the search, clicking on No button. In

the last case, a protocol containing only the connection error will be created.

The Print no match button generates a pdf file that contains only the KO outcome.

2.3 Protocol Printing

Using the button, you can create a PDF file and save it in a local environment, from

where it can be sent to print.

The following screen will appear, here it is possible choose the list to be printed, among

these selected in the enquiry criteria (see paragraph 2.1). Only one list is allowed at a time.


The following figure shows an example of pdf files for printing the result of the Natural

Person “Ahmed” query. In this case the option “UIF/UE/UNSC/OFAC lists” has been

selected.

It is recalled that the outcome Neg. displayed in the report is just a default value; each User

is responsible for deepening, confirming, or excluding the possible matches highlighted.


The button , placed above the Name list, makes also possible to extract all the

names being part of a list in a pdf file. Please note, however, that the protocol will then be

archived (see paragraph 5) and it will be no longer present on the list of the management

protocols. It can be reached only in the Research section (see paragraph 6).


3 Batch Comparison (Matching)

The “Matching” Check-in comparison is a process that is not processable by the User. This

is a massive comparison, or by difference, between the directory of company records and

the subjects present in the reference lists. It is carried out daily through a computer process

for the Company-new registry.

The process produces automatically the protocols, which are displayable on the section:

“Case Management – by Matching”. Each protocol may contain at most 30 match, for this

reason many protocol can be created for each enquiry.

The batch comparisons can be on:

1. All internal registers with all the names in the lists

2. All the internal registry with the delta (i.e. the changes) of the lists

3. Internal registry delta with all the names in the lists

The protocols produced by the batch are available and evaluable in the section of Case

Management in the same manner as those generated by manual check-in. The only

operating modes specific to these practices are those inherent to the:

• Generation of the reports;

• Consultation of the lists;

appropriately explained in the next paragraph 4.2 e 4.3, dedicated to the Outcome Report

and their details.


4 Outcome Reports and Detailed Tables

4.1 Reading a Protocol

The Subjects extracted by the queries are inserted in a protocol.

In case of Manual Check-in, the user is automatically addressed to the protocol that contains

the results. The example below resumes the protocol generated by the research of the Natural

Person Ahmed (see paragraph 2).

If you want to consult a protocol previously created (manually or by batch), you have to

access the “Case Management” section. Here it is possible to choose the source of the

protocols.

Beside the two options described before (By Manual Check-In and By Matching), the user


can choose two other sections: By User and Search. The first option shows all the protocols

open by or in charge to the logged user (both from manual or batch source), while in the

second one the user can execute a search query using different filters (denomination,

protocol, date).

Depending on the choice of the source, the corresponding protocol list will be shown (see

following screens):

The bottom left section, below the list of subjects, gives details of the selected protocol,

while the bottom right section can be ignored.

Selecting a protocol and clicking on Open button, or clicking twice on a protocol, it will be

possible to visualize its details.


On the top of the screen are shown the information of the Subject of the enquiry (in this

case Ahmed), while on the bottom are listed all the Names extracted list by list (on the right)

and the lists on which the search was made (on the left).

By clicking on a subject's record, you can go to the parameters of the request:

Clicking on a name row, or on Open button, it will be possible to display the details of the

form


In case of Natural Person Query, in this section will be available two more buttons: Personal

Data and Alias.

The Personal Data section shows the personal data of the customer, as the tax identification

code, the date of birth and the place of birth.

The Alias section shows all the other denominations (nicknames, past names, misspelling of

names, etc.) eventually associated to the subjects extracted by the query. It lists the

denominations, the role, and the person type (natural or legal person). The role value point

out when the denomination is a real Name and Surname (value “2”) or is just a nickname

(value “5”).


These two section are instead not available in case of Legal Person query.

The Document/Communication section shows the documentation of the legal action

against the subject of our research. Clicking on Open, a PDF file containing this information

will be shown (when available on the list). For instance, the EU source makes available the

detail of the European Community Journal containing the searched names. This is true both

for Protocols generated by matching and for those generated by manual check-in.


Please note that the card will have different features for each list. Here below is shown an

example of new List “VMS PROCUREMENT”.

4.2 Outcome Reports

Opening a protocol, it is possible to note, on the lower left corner, three buttons: Protocol,

Management and Communication.

The Management section is the default one on which you are automatically directed when

a protocol is open.


In the upper left side of the screen there is an additional menu, constiting of four buttons:

Valutazione soggetti (Subjects evaluation), Attachments, Events and Notes.

In this paragraph, we will only deal with the content of the section Attachments for the

protocols generated via batch (matching). For these protocols, two reports are available,

which detail the matching details. The other sections will be explained in the next

paragraphs.


The report details are available clicking on Open button.

The reports show the batch matching comparison, according to two different point of view.

1. The Report 1 displays the subject of the institutional blacklists that has been

searched in the Company register;

2. The Report 2, on the other hand, displays the subject of the Company Register that

have been checked on the institutional blacklist.

Selecting one report and clicking on Open, it will be possible to esaminate its detail.


As can be seen, the report headers are similar: they show the source of the list, the register

of companies in question and the comparison type performed by the batch. Only the last

line shows the type of report that is exposed.

The body of the report, instead, differs for the sort of information.

The report 1 shows, list by list, all the Names present in them for which a correspondence

has been found in the register of the Company in question.

For each list are shown the regulations and any associated communications (1), then all the

details of Subjects for which a correspondence has been found: the identify code present

on the list (2), the text of the list (3), all the associated Names and Alias (4), the likeness

accuracy (5).

Instead, the report 2 shows, for each nominative present on the Company registry, all the

subjects in the lists for which a match has been found.

For each Names on the Company register are shown: the likeness accuracy (1), the list of

the subjects and its alias (2), the list identifier (3), the original text of the list (4), the list

number (5) the regulations and any associated communications (6).


4.3 Report Details

Further informazion about the elaboration that has generated the protocol can be found in the Protocol section.

This section shows the details of the query that generated the protocol.

When analysing a protocol created with Manual Check-In, the following screen will appear,

where it will only possible to visualize the detail of the query that generated the protocol,

as the subject names and the personal type.

When analysing a protocol created via batch (Matching), the same click will instead open

the following screen, which shows the details of the batch enquiry:


Clicking on Report details, a screen with a detail of the elaboration will be shown:

The Report Id cell give information about the typology of report.

The three rows on the bottom summarize the results of the batch query:

• The first number (checked person) shows the number of the subjects contained in the

lists

• The second (Master data) shows the number of subjects listed in the master directory

of the Customer

• The latter (person identified in master data) shows the number of subjects who have

been found compatible with the query parameters in the master directory.


5 Case Management

5.1 Results Evaluation

The evalutation of the protocol can be done both from the Case Management section,

clicking on Valutazione Soggetti button, and, only in case of manual check-in, directly from

the outcome screen of the enquiry (see figure below).

Let reconsider the protocol outcome from the Natural Person Ahmed enquiry, exposed in

paragraph 2:

Here it is possible perform the evaluation of the subject names found in the lists.

The button , placed on the left above the list of the sources,

gives negative result to all the sources. This implies that the searched subject has not been

found in any of the lists.

The button , placed on the right above the list of names, gives

negative result to all the names in a single list. It requires the insertion of an evaluation

note.

Each evaluation of a subject must be substantiated by entering a note. In this way, it would

ever be possible to record the decision-making process that led to the positive evaluation.


A drop-down menu is also available on every name with the allowed values for the

evaluation:

For subject evaluation, the user can:

• Click on Positive when the subject is matching;

• Click on Doubt when a further internal analysis is needed;

• Click on Negative when the subject isn’t matching or isn’t present in the anagraphic lists.

The Doubt button can be used in case that the user needs other information to establish the

subjects positivity or negativity.

When the user must remove a doubt evaluation of a single subject, he must select the subject

record, click again on “Doubt”, and insert a new evaluation note. As result, the doubt evaluation

mark will be removed. Only the note previously inserted will remain in the chronology history.

In fact, when the user proceeds with any evaluation action, the notes previously inserted will be

kept in the chronology, to record the whole progress of the evaluation process.

When a subject has been evaluated as positive or doubt, two new buttons become available:

Save Assessment and Cancel Assessment.

Save Assessment button confirm the evaluation of the subjects. It is necessary to insert an

evaluation note.

If you proceed with a revaluation, the notes you have already entered will not be deleted,


but will keep track of the considerations previously made.

The Cancel Assessment button allows the annulment of the positive or doubtful evaluation

previously established, unless a note has been already inserted. In this case the Cancel

Assessment button is no longer available.

Please note that the appropriate documentation must be produced and stored in support

of the evaluations carried out, as the system evaluation is not sufficient unless it is covered

by the relevant documentation.

5.1.1 Subjects Revaluations

The revaluation of a protocol previously evaluated, or partially evaluated, can be done

accessing to the Valutazione soggetti (Subjects evaluation) section within the Case

Management.

The display is similar to the output of a manual search: at the top are the names of the

Subjects, in the bottom are the names that are extracted from the lists.

Here you can perform the evaluation operations explained in the previous paragraph.

Moreover, In the Valutazioni Precedenti (Previous Evaluations) section, the user can verify

if the subject extrapolated by the enquiry has already been investigated.

When a previous valuation already exists, this section will show some details as the

evaluation date, the user name who performed the evaluation and the associated name:

Otherwise the following screen will be shown:


5.2 Other Options in Case Management Menu

Beside the Subjects evaluation and the reporting dedicated to the protocols created by

matching (see paragraph 4), the Case Management Menu provides other options, as:

attachment of documents, visualization of the events and insertion of notes.

5.2.1 Attachments

In this section the user can attach to the protocol all the documents that he will consider

necessary to motivate his proper evaluations.

Clicking on New, the user can import the files choosing them from his PC and then clicking

on ADD button.


Once the import of the file is confirmed (clicking on OK), the following screen will appear:

Here the user can valorise the fields Nome and Descrizione. The Importa button will at last

conclude the file attachment to the protocol.

5.2.2 Events

In this section the user can visualize the events related to the protocol process, and the user

who carried up them:

Clicking on New button it is possible to add an event that was not automatically inserted,

for example to keep track register of a phone call or of an email:

It is possible to insert a Note to record the content of such communication.


5.2.3 Notes

In this section the user may insert the notes related to the protocol he is working on.

Clicking on the following screen will appear:

It is possible to insert a short explanation in the field Description.

The note text may be insert in the field below. Then, clicking on Add button, the entry is

confirmed. Clicking on Cancel, instead, any note will be inserted and the screen will be

closed.

To delete a note previously inserted, the user must click on button.

5.3 Protocol Management and Archiving

In this section are introduced the rules which make possible to set up and monitor the

process of the protocols, both when they were created in the Manual Check-In section or

in the Matching section. The protocol phases are the following:


▪ Checking da fare: this is the first phase of the protocol, since it has been generated.

▪ Checking in Lavorazione: as second step, the protocol pass in this phase when the

subjects extracted by the query has been evaluated.

▪ Checking Sospeso: clicking on Suspend button the evaluation process is no more

available for the user. The Reactivate button make possible the reprise of the

evaluation process.

▪ Results (positive or negative) da fare: clicking on Forward button, the protocol passes

automatically in the Results phase.

▪ Results Sospeso clicking on Suspend button the evaluation and the case filing

processes are no more available for the user. The Reactivate button make possible

the reprise of both processes.

▪ Case filing clicking on Close button, the protocol will be archived.

The management of the protocols in the list is carried out with the buttons placed on the

toolbar on top of the screen:

The Forward button allows to the user to send a protocol, if it is already fully evaluated. The

protocol status passes then to the Results phase, which could be positive, negative o

doubtful according to the opinion of the user. Once the protocol is on the Results phase,

two more buttons will be available by the user: In verification and Close.


The button In verification brigs back the protocol status to “In lavorazione”, cancelling the

previous “Forward” operation. The Close button will file the protocol (see Paragraph 4 for

further details).

The Colour button assigns a colour to the selected protocol row, only for highlighting

purposes. Each protocol generated via batch and containing at least a subject (physical or

legal person) will be automatically highlighted with the orange colour. Orange is the default

colour provided in the standard installation; it is anyway possible to change it in the

installation settings.

The Print button allows to create a pdf file, that contains information over the selected

protocol (see paragraph 2.3).

The Completely negative button allows to evaluate as negative all the subjects listed in the

selected protocol, without accessing it directly. The consequence is the same that is

provided by the button “Negative assessment (all sources)”, already explained in the section

5.1.

The Suspend button put the protocol in suspended phase, both when the protocol is still

under evaluation and when it is already in the Results phase. To resume the evaluation, the

Reactivate button will be available. It will appear in the toolbar when a suspended protocol

is selected:

At the end of the evaluation phase, the user must click on Forward to move on the protocol

to the Risultanze in Lavorazione phase.

If all the requested evaluations are carried out, the protocol will move on automatically to

one of the following phase:

• Positive Results

• Negative Results

In accordance to what the user has fixed during the evaluation process.


Clicking on Yes, the user confirms the transfer to the Outcomes phase and proceed with the

protocol archiving.

To proceed with the closure of the protocol, the user will click on Close button: the following

screen will appear, on which the user must confirm his closing request.

When a protocol contains some subject names evaluated as doubt, it will be saved as

Dubious Results (da Fare). It is possible to Forward the dubious protocol, which status will

pass on Dubious Results (In lavorazione), but it is not possible to close it until all the doubts

will be fixed. Trying to close a protocol with persisting doubt will make appear the following

warning message:

To revaluate a subject, the user must click on Open button to access the protocol and

complete the evolution of the doubt cases.

5.4 Protocol Cancellation

The Delete button is placed on the toolbar at the top of the screen.

According to the protocol status it will be possible:

• Cancel the protocol, filing it as cancelled. It will be possible to recuperate it in the

Research section (with status Archiviata Annullata);

• Delete the protocol. In this case the protocol will be physically deleted, and it could

no longer be restored.


The user can delete the protocols only when they are still unevaluated. In fact, when the

protocol is already in Results phase (doubtful, negative or positive), it can be cancelled but

not deleted.


6 Research

In this section, the user can perform a research of the protocol previously open, evaluated

or filed, both from Manual Check-in and from Matching.

On the upper side of the screen the user will find some filters that allow to start a specific

research. The resulting list of protocol will be available on the bottom side of the screen.

The research can be done according to the following filters:

• Name: the user must insert Name and Surname of a physical person or the

denomination of the legal person. The Name may also be partially inserted.

• Protocol: the user must insert the protocol ID. The value must be exactly inserted.

• Protocol Name: the user must insert the name of the protocol. A partial insertion of

the name is allowed.

• Date: the user can insert a single date or a period (from… to…).

• Subject: the user must insert the subject NDG.

• Step and Status: the user can insert the Type, Step and Status of the protocol to search

for. The values to be inserted are not free, but they must be chosen from a drop-down

menu.

COMMA CHECK-IN - Check Lists · Manuale Operativo Comma Check-In 11 3 Batch Comparison (Matching)...

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Transcript of COMMA CHECK-IN - Check Lists · Manuale Operativo Comma Check-In 11 3 Batch Comparison (Matching)...