Sanctions risk assessment: What is involved?

Is is considered best practice to align a firm-wide sanctions risk assessment with the requirements of the MLR2017. These regulations outline several risk factors that should be taken into account. They include:

your firm’s clients
Regions or locations where your services are conducted
Offerings or services provided by your firm
Transactions conducted by your company
The methods through which your firm delivers its products and services

The risk assessment must align with the scale and scope of your practice, considering any factors that may influence risk, such as:

number of staff
areas of work
geographic location of offices
supervisory structure – this might, for example, include whether your firm works remotely, whether you have overseas offices, and what level of oversight senior staff have of fee earners.

Whatever you decide, if your firm is CQS accredited, make sure you update your CQS AML Policy

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