One of the most asked questions we get via email is “Do you sell money laundering risk assessment documents?” If you are a firm or sole trader who has obligations under the Money Laundering Regulations (MLR), then you are going to need to have such ‘documents’ in place.
Financial Crime Risk Assessments
Financial crime encompasses money laundering, fraud, tax evasion, bribery and corruption, terrorist financing, proliferation financing and any other crime related to finance and money. A risk assessment is a tool for identifying, assessing and managing the risks associated with this areas.
Those with obligations under the MLR must carry out a business-wide risk assessment to identify areas of vulnerability relating to money laundering and finanical crime. These risks can then be mitigated through controls, systems and procedures. Supervisory authorities such as HMRC and the FCA also require a firm to complete a money laundering risk assessment at least annually.
AML Risks to Consider
Any risk assessment is a pre-emptive approach to risk and allows a business identify the risks and apply corrective actions before negative outcomes occur. Effective mitigation of AML risks should result in either accepting, eliminating, reducing or managing risks. Where money laundering risks are concerned, there are a number of areas and criteria that need to be considered. These include, but are not limited to: –
- Who are your customers?
- Who are your suppliers?
- Third-party relationships
- Geographical locations
- Your products and services
- Delivery channels
- Customer source of funds
- High value customers
- Transactions & payment processes
- Sanctions lists (i.e. FATF register)
- High-risk customers (i.e. PEP’s)