What is Risk Assessment (1)
Over the past few months, the importance of risk assessment as one of the measures to combat money laundering has been emphasized in seminars held by HKC&ED and HKMA seminars as well as report issued by the Financial Action Task Force.
As a matter of fact, licensed MSOs can make use of risk assessment to determine the money laundering/terrorist-financing risk level of customers. Based on the risk level, resources can be allocated accordingly for performing customer due diligence and ongoing monitoring. It is crucial for licensed MSOs to take relevant effective measures in order to prevent from violation of law.
Licensed MSOs should conduct risk assessment once they start to establish business relationship with customers. After the assessment, customers should be categorized as different risk levels such as high, medium or low. While factors used for risk assessment varies depending on the industry and the nature of organization, factors that may be considered include:
- Country risk (subject to high levels of organized crime, increased vulnerabilities to corruption, for example Iran, North Korea, Afghanistan)
- Customer risk (For example Politically Exposed Persons (PEPs), non face-to-face transactions, source of wealth cannot be easily verified)
- Product/service risk (that inherently have provided more anonymity, for example Bitcoin)
- Delivery/distribution channel risk (For example sales through online, postal or telephone channels, business sold through intermediaries)
To be continued......