To complement our anti-money laundering policy for a low risk business, a new company wide risk assessment and a client identification checklist have been added to the corporate portfolio of templates.
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 clients’ identities 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 considered a matter of good corporate governance 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 client 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 client’s identity, allows a company to properly assess the level of risk associated with doing business with that client and formally record it.
These templates must be tailored to each specific company 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.