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New Customer Checklist and Risk Assessment

March 2020

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 legal matter.

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