AML Client & Matter Risk Assessment

In compliance with Regulation 28(12) & (13) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017

Client's full name:

Client's date of birth:

YYYY

Client's address:

I have seen and retained copies of the following documents:

Customer due diligence means taking steps to identify your customers and checking they are who they say they are. In practice this means obtaining a customer’s: name photograph on an official document which confirms their *name*, *residential address* and *date of birth*. The best way to do this is to ask for a government issued document like a passport or driving licence, along with utility bills, bank statements or other official documents.

Passport

Driving licence

Utility bill

Bank statement

Other (specify below)

CLIENT RISK

Is the client new or existing?

Client's Occupation / Source of income:

Does the client own, manage or direct a business or activity that falls within a higher risk industry?

Examples include: - Crypto industry and cryptocurrencies; - Dating/adult industry; - Arms trade; - Casinos; - Cannabis/CBD industry (also the cannabis paraphernalia industry); - Certain licensed companies (e.g. forex investment fund); - Gambling/iGaming industry; - Money Transfer businesses; - Precious Metals; - Companies that do business in high-risk countries (typically disallowed by traditional banks); - Import/export companies with a very high monthly transaction volume;

Is it unusual for this type of client to instruct us?

Do you have any concerns about the client? (e.g., capacity, undue influence, vulnerability)

If a third party is instructing, do you have evidence of their authority to act?

Is the client a designated person/entity (i.e., listed)?

Is there adverse media about the client?

That is, is there any negative or damaging information about the client that is publicly available through various sources such as news articles, social media, regulatory filings, court records, and other open sources?

Is the client a Politically Exposed Person (PEP)?

PEPs can be: • heads of state, heads of government, ministers, and deputy or assistant ministers • members of parliament (MPs) • members of courts of auditors or of the boards of central banks • ambassadors, chargés d’affaires and high-ranking officers in the armed forces • members of the administrative, management or supervisory bodies of state-owned enterprises • members of supreme courts, constitutional courts or other high-level judicial bodies whose decisions are not generally subject to further appeal, except in exceptional circumstances PEPs also include: • the person’s family members • close business associates • beneficial owners of the person’s property (someone who enjoys the benefits of ownership even though the title of the property is in another person's name)

Is the client subject to financial sanctions?

The UK's high-risk third countries for anti-money laundering (AML) purposes are set out in the Financial Action Task Force's (FATF) lists on 'jurisdictions under increased monitoring' and 'high-risk jurisdictions subject to a call for action'. For an up-to-date list, check: https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html

In which country is the client based?

Do you have any concerns about the client’s location?

Does it make sense for the client to instruct us from this location?

Overall, what level of risk is posed BY THE CLIENT?

MATTER RISK

Matter Reference:

Matter description:

What is the total transaction value of the matter?

Do you usually carry out this type of work?

Does the matter involve creating a complex structure?

Does the matter involve a cash-intensive industry?

Does the matter involve a high-risk industry?

Does the matter involve a risk of proliferation financing?

Are there any overseas elements in the matter?

Are there any other AML or Counter Terrorist Financing risks?

Have you checked the source of funds for this transaction?

Are we receiving funds from overseas?

Are we receiving funds from a third party?

Overall, what level of risk is posed BY THE MATTER?

What level of customer due diligence will you apply?

Notes:

Assessment conducted by:

First Name

Last Name