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Risk Assessment: a tool

AML requires you to carry out a risk assessment when establishing a new client relationship. To support you in this, we have prepared a document to help you determine whether you are dealing with a low, medium or high risk client. The document contains questions you can answer, after which a score is calculated to easily determine the risk level. 

 

Important remarks

Before introducing the document, it is important to stress that this is only a guide. The risk factors and weightings are indicative and should be adapted to your firm's policy. It always remains your own responsibility to make an individual analysis of each situation and consider all available information before making decisions. 

In addition, it is crucial that, besides complying with the various AML requirements, you also check whether the (potential) client or person involved is on a sanctions list. If this is the case, you are generally obliged not to continue the service.

 

The questions

The document consists of a series of questions and scoring that you can then use to calculate an overall score. The questions focus on different risk factors. Below is a brief list of some of the questions included in the document: 

  • Starting the relationship: did you see the client face-to-face, remotely, or not at all? 
  • High-risk countries: is the client located or resident in a high-risk money laundering country? 
  • Politically Exposed Persons (PEP): is the client a PEP or a relative thereof?
 
The scores 

After you have answered the questions and calculated the total score, you can compare it with the different categories. When doing so, use the following guidelines: 

  • Total score from 0 to 49: low risk 
  • Total score from 50 to 199: normal risk 
  • Total score from 200 onwards: high risk  

These categories should be integrated into your AML policy. In doing so, note the appropriate measures for each risk level.

 

Risk Assessment Tool

Using this document, you can conduct an effective risk assessment under AML However, it is very important to be aware of the indicative nature and the need to analyse each situation individually. Always remain alert to changes in laws and regulations and adjust your AML process and policy accordingly.

Door een grondige due diligence en risicobeoordeling uit te voeren, vervul je niet alleen jouw wettelijke verplichtingen, maar draag je ook bij aan het bevorderen van een integere en veilige financiële sector. Zo werken we samen aan een solide verdediging tegen witwaspraktijken en terrorismefinanciering. 

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