AML Firm-Wide Risk Assessments - Your Annual Review & Update

Introduction

A firm-wide risk assessment is the backbone of an effective AML framework. It should shape the policies, controls and procedures a business adopts, the training it provides and its approach to assessing and managing customer, client and transactional risk.

It is not, however, a document that can simply be prepared and filed away.

Regulation 18 of the Money Laundering Regulations 2017 requires relevant businesses to identify and assess the risks of money laundering and terrorist financing to which they are exposed. The assessment must be kept up to date and take account of relevant information made available by the appropriate supervisory authority.

Businesses must also respond to changes in national and sectoral risk assessments, regulatory guidance, criminal methods and their own services, customers and delivery models.

Current and emerging risks include AI-enabled impersonation, remote onboarding, cash-intensive businesses, complex ownership structures, reliance on previous due diligence, sanctions circumvention, proliferation financing, cryptoassets and global instability.

Presented by Jo Morris, this new virtual classroom seminar will guide MLROs, compliance officers and others responsible for AML compliance through a structured annual review of their firm-wide risk assessment. It will help you identify what has changed, determine which developments are relevant to your business and maintain an appropriate record of your decisions and resulting actions.

What You Will Learn

This live and interactive session will cover the following:

• Why the firm-wide risk assessment is the foundation of your AML framework
• Regulation 18 of the Money Laundering Regulations 2017
• When should a firm-wide risk assessment be reviewed?
• What events should trigger an additional review?
• Reviewing the latest risk information:
• The National Risk Assessment
• Sectoral risk assessments
• Guidance and publications from supervisory authorities
• The findings of thematic reviews and enforcement action
• International risk information and emerging criminal typologies
• What has changed since your previous review?
• Deciding which developments are relevant to your business
• Revisiting the five principal risk areas:
• Customers and clients
• Countries and geographical areas
• Products and services
• Transactions
• Delivery channels
• New and developing risks, including:
• AI-enabled impersonation and deepfakes
• Remote onboarding and digital identification
• Reliance on existing or third-party due diligence
• Cash-intensive businesses and nominee arrangements
• Complex corporate and beneficial-ownership structures
• Cryptoassets and alternative funding arrangements
• Global instability and higher-risk jurisdictions
• Proliferation financing
• Sanctions evasion and ownership and control
• Inherent risk, mitigating controls and residual risk - understanding the distinction
• What internal information should inform your review?
• Changes to the business’s services, locations and customer base
• Customer, client and transactional risk-assessment data
• Suspicious activity reports and internal disclosures
• Declined, terminated or aborted business
• Compliance breaches, incidents and audit findings
• Management information and feedback from operational teams
• Testing whether existing risk ratings remain accurate and defensible
• Using templates without producing a generic assessment
• Recording why a published or emerging risk is - or is not - relevant to your business
• Linking the updated assessment to:
• Policies, controls and procedures
• Customer, client and transactional risk assessments
• Customer due diligence and enhanced due diligence
• Ongoing monitoring
• Staff training
• Compliance monitoring and independent audit
• Senior-management review, challenge and approval
• Preparing an annual review record and action plan
• Practical case study - updating a firm-wide risk assessment following changes in the external risk environment

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.