What is Risk Assessment (2)
After risk assessment, companies should formulate different policies, procedures and supervisory controls based on different risk levels in order to monitor customer transactions and perform on-going reviews (e.g. high risk customers should be reviewed annually). Assessments will change over time, depending on how circumstances develop, and how threats evolve. Therefore, licensed money service operators have to adjust its risk assessment of a particular customer from time to time and keep its policies and procedures under regular review and assess that its risk mitigation procedures and controls are working effectively.
Licensed MSOs should maintain relevant records and documents and should update them regularly based on different risk levels in order to show HKC&ED and regulatory departments:
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How customers' anti-money laundering/counter terrorist financing risk have been assessed; and |
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Adequate due diligence and on-going monitoring have been performed based on respective customers' anti-money laundering/counter terrorist financing risk level. |
During an anti-money laundering seminar held in mid-October, officers of the Hong Kong Monetary Authority emphasized the importance of risk assessment. Risk assessment helps banks better understand their risks associated with money laundering and formulate relevant measures to manage risk. As banks are investing more resources into measures such as risk assessment, licensed MSOs should cooperate and conduct comprehensive assessment on their own operations as well as customers based on the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance. A certain risk level should be allocated and according to the degree of risk, customer due diligence and on-going monitoring should be conducted and relevant records and documents should be kept. Review of the effectiveness of the risk assessment system should be performed from time to time.
(Please note that above information is for reference only.)