AML Client & Matter Risk Assessments - Lesser Known, But Equally Important

Introduction

The SRA Annual AML Report says that during the reporting year out of 1245 files reviewed in their visits, 51% of the client/matter risk assessments reviewed were inadequate. 27% of them did not reflect the firm’s firm-wide risk assessments, 43% didn’t show when enhanced due diligence was required and 21% of the files didn’t have a client/matter risk assessment at all! There is much room for improvement and the SRA released three documents in October 2023 to help us with this.

There are several levels of AML risk assessment that firms must be aware of.

The highest level of risk assessment is the National Risk Assessment (NRA) and covers all sectors who fall under the money laundering regulations.

The next level of risk assessment under Regulation 17 MLR2017 is the sectoral risk assessment which is conducted and published by the regulatory bodies.

Regulation 18 of the MLR 2017 made it a legal requirement to have a firm-wide risk assessment but this isn’t the only risk assessment that we must put in place.

We also need to ensure that client and matter risk assessments are undertaken and kept up to date.

This new virtual classroom seminar will show you how and ensure that they are not just a tick box exercise.

What You Will Learn

This live and interactive session will cover the following:

• What needs to be considered when putting together a client and matter risk assessment - client, location, PEP, source of wealth and source of funds
• Templates?
• What does the relevant guidance say?
• Relevant questions to ask to determine risk - not just a tick box exercise
• Difference between a person and entity client and matter risk assessment
• Ongoing monitoring of risk
• Additional information that may be included on these risk assessments

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.