ANTI-MONEY LAUNDERING AND COUNTER

TERRORISM FUNDING ANNUAL MONITORING

REVIEW

Ref
Prepared by
Date
Reviewed by
Date

YES
1. Has there been any change to the Money
Laundering and Terrorism Funding Risk
Profile?

NO

COMMENTS

If yes, review adequacy of the client due

diligence information on file and ensure it
is all fully up-to-date (including Passport
information being current. Obtain any
required information relevant to risk
category including information not
present because it was not previously
required.
2. Have any new senior management been
appointed?

N/A

N/A

N/A

If yes, consider whether they are a PEP.

Obtain any required due diligence
information relevant to risk category
3. Are there any new shareholders holding
more than 10% individually or 20% in
aggregate, or new controlling parties?
If yes, consider whether they are a PEP.
Obtain any required due diligence
information relevant to risk category
4. Are there any changes in the clients
strategy or business profile? Such
changes could include new geographic
markets, new product lines/services
offered, major changes in terms of trade
or trading methods (particularly where
terms of trade could have transfer pricing
issues), major new customers or
suppliers, new branches, subsidiaries,
associates or joint ventures (particularly if
outside EU), new significant related
parties (particularly if third parties have
significant involvement in related party),
If yes, and these changes have not
affected the Risk Profile per 1. above,
review the due diligence information and
update any out-of-date information as
appropriate.

Z0034
MKS
16/11/2015

MONEY LAUNDERING AND TERRORISM FUNDING RISK

PROFILE

Ref
Prepared by
Date
Reviewed by

Z0034
MKS
16/11/2015

Date

Factor
Lower Risk
Location of business
operations, control
and ownership
Complexity of
business
Trade

Management

Services taken

Ownership

Indication of
Higher Risk

UK, EU or other onshore country

with low corruption risk

Country with high risk of corruption

or offshore financial centre

Single entity or group with no

minorities holding individually
>10%, or >20% in aggregate
Largely credit-based

Complex group structure with

operations in high risk locations or
with SPVs
Largely cash-based

Products/services with low risk of

fraud or usefulness to terrorism

Products/services with high risk of

fraud or usefulness to terrorism

Transactions largely connected to

principal activities
Largely UK resident

Many transactions with little or no

apparent commercial purpose
Largely non-UK resident

Owner-managed or managed by
professional managers

Heavy use of non-executive

management or management with
little commercial involvement in
operations

Low management turnover

Normal range of services taken

High management turnover

Services taken limited for no
apparent reason, e.g.:
Company/trust formation only
Company secretarial /trust
management services only
Audit of only part of a group
where we could audit the
whole group
One-off, high-risk assignment
where normal advisors could
do the work
Ownership includes PEPs or
people/entities with a high risk
profile

Owner-managed where owners do

not have a high risk profile

Risk
(H,M or L)
L
L

L
Initial contact

Standard Due Diligence

applicable where risk is
low; enhanced where
high. Where risk is
medium, use
judgement to decide
appropriate level and
document reason if risk
assessed as low

Complex ownership structure

involving trusts or offshore entities
Face-to-face
Not face-to-face
Overall Risk
(NB Always High if contact not face-to-face or PEPs involved)
Standard Due Diligence (Tick) and reason if indications of higher risk
present:

Enhanced Due Diligence (Tick)

L
L

N/A

N/A