What does an AML/CTF risk assessment look like for an accounting firm
The risk assessment is the cornerstone of your AML/CTF obligations.
Why is it important? Your risk assessment justifies why you classify certain clients as low, medium or high risk, the level of customer due diligence you apply, and therefore where you need to invest your resources. A sensible, honest risk assessment is essential to ensure you have a proportional and compliant approach to your AML/CTF obligations.
What should your risk assessment cover ?
The legislation prescribes that a risk assessment must have regard to:
Client type (individual, company, trust, overseas entity).
What Designated Services you provide (company formations, trust management, client funds).
what jurisdictions you interact with (local vs overseas).
the delivery method you use for your services (face-to-face vs remote).
What guidance is available?
Some accounting peak bodies have provided example risk assessment matrices for smaller practices, however the approach from most regulators has been generic.
Your risk assessment is your roadmap. Without it, your AML/CTF program will lack structure.
We recommend:
Getting the best data you can about the risk factors
Runing a risk assessment workshop.
Use a recommended risk scoring matrix.
Document the rationale for selecting something as low/medium or high risk.
We can help with all of this – register for a webinar or give our AML/CTF team a call.
Paul Gray
Principal
T 03 5225 5231 | M 0414 195 886
E pgray@ha.legal
Hugo Le Clerc
Senior Associate
T: 03 5225 5213 | M: 0438 089 334
E: hleclerc@ha.legal
