Importance of General Sensitivity in Risk Assessments for AML Compliance

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Learn why general sensitivity in client and matter risk assessments is crucial for regulatory compliance, decision-making, and promoting good business practices in financial institutions. Understand key takeaways and good practices to ensure effective risk management.

  • Risk assessments
  • AML compliance
  • Financial institutions
  • Regulatory requirements
  • Client due diligence

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Presentation Transcript


  1. Sensitivity: General Client and matter risk assessments Declan Brown, AML Regulatory Manager Michelle Clement, AML Regulatory Manager

  2. Sensitivity: General Why is it important? Regulatory requirement Decide whether to accept instructions Decide level of client due diligence required Promote good business Financial sanctions risks

  3. Sensitivity: General Thematic review 94% of firms had a process Nearly half (47%) files didn t have a client/matter risk assessment Outcomes

  4. Sensitivity: General What it isn t! E-verification system rating Business risk assessment red tape exercise

  5. Sensitivity: General Good Practice Recording rationale Tailored templates Review at appropriate intervals

  6. Sensitivity: General SRA Template ABC LLP is a law firm based in Bristol Client based in Birmingham 250,000 residential property purchase in Birmingham 25,000 deposit from client, alongside 225,000 mortgage

  7. Sensitivity: General Key takeaways Do it every client, for every matter in scope of the MLR Make sure the relevant people know how to access it Make sure the relevant people can read and understand it Write it down

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