New Customer Checklist and Risk Assessment
Risk assessment and customer due diligence is an essential part of any
anti-money laundering compliance process; to understand whom a business is
dealing with, their activities and to check their identity. This month a
new business wide risk assessment and a customer identification checklist
have been added to the business portfolio of templates to complement the
anti-money laundering policy for a low risk business.
A low risk business is one that is not regulated under current legislation
and therefore not required to carry out a risk assessment or check
customers’ identity in line with the Money Laundering, Terrorist Financing
and Transfer of Funds (Information on the Payer) Regulations 2017 as
amended by The Money Laundering and Terrorist Financing (Amendment)
Regulations 2019. However, it is a matter of good business practice and
sensible for all businesses to consider having policies and procedures in
place to identify and minimize the risks of money laundering. This includes
a risk assessment and customer identification checklist.
A formal risk assessment allows a business to consider and identify the
risk factors that it may be exposed to and take steps to mitigate.
Likewise, due diligence to establish and check a customer’s identity,
allows a business to properly assess the level of risk associated with
doing business with that customer and formally record it.
These templates must be tailored to each specific business and circumstance
and are not exhaustive.
The contents of this Newsletter are for reference purposes only and do not constitute
legal advice. Independent legal advice should be sought in relation to any specific