Customer Risk Rating Methodology Template (AML/KYC)
AML customer risk rating: factors and weights, scoring formula, automatic triggers, bands and CDD levels, worked examples, overrides, review cycle, validation
Mode d'emploi: Use it when a compliance team defines or revalidates how every customer receives an ML/TF risk rating. Set factor weights from the business-wide risk assessment first, then the bands, and test them on the real portfolio with outcome analysis. The main pitfall is weights tuned until the high-risk share looks right, with no documented rationale or override control.
Aperçu
Customer Risk Rating Methodology: [Institution name]
The documented method an institution uses to give every customer a money laundering and terrorist financing (ML/TF) risk rating: scope and rating points, risk factors and weights, scoring formula, automatic triggers and prohibited relationships, rating bands and the due diligence level each band requires, overrides, review frequency, data lineage, validation and change control. Based on public law and guidance as of 2026-10: national law transposing Directive (EU) 2015/849 (Art. 13 and Annexes I to III), Regulation (EU) 2024/1624 (AMLR) Art. 20(2), Art. 26 and Annexes I to III from 2027-07-10, the EBA Guidelines on ML/TF risk factors (EBA/GL/2021/02, as amended), the US customer due diligence requirement to develop a customer risk profile (31 CFR 1020.210(a)(2)(v)(A)) and UK MLR 2017. FATF Recommendations 1 and 10 are cited by number and title only. Replace every
[bracketed]value and every row marked Example. This is a document format, not legal, regulatory or financial advice. Obtain the law or standard for the normative text and check local law.
Document control
| Field | Value |
|---|---|
| Document ID | [MTH-CRR-001] |
| Institution | [Legal name] (Example: Fernhollow Bank) |
| Entities in scope | [Parent, subsidiaries, branches] |
| Version | [2.0] |
| Status | [Draft / Approved / Superseded] |
| Owner | [@mlro] |
| Approvers/reviewers | [@compliance-manager], [@model-risk-management], [@head-of-kyc], [@data-owner] |
| Implementing system and version | [Scoring engine name, release] |
| Model inventory ID and tier | [MOD-ID], [Tier] |
| Effective date | YYYY-MM-DD |
| Last updated | YYYY-MM-DD |
| Next scheduled review | YYYY-MM-DD (at least annually and after each business-wide risk assessment) |
| Classification | Confidential; weights and thresholds not shared with customers |
| Policy reference | AML/CFT Programme Policy (compliance/aml-cft-programme-policy), section 5.3 |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| MLRO (owner) | [@name] | [Approve] | YYYY-MM-DD |
| Model risk management (independent review) | [@name] | [Validated / Conditions] | YYYY-MM-DD |
| Compliance manager | [@name] | [Endorse] | YYYY-MM-DD |
| Head of KYC operations (implementation) | [@name] | [Accept] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change |
|---|---|---|---|
| 1.0 | YYYY-MM-DD | [@mlro] | First issue |
| 1.1 | YYYY-MM-DD | [@mlro] | Geography scores updated after list change |
| 2.0 (Example) | 2026-10-25 | [@mlro] | Channel weight reduced from 20% to 15% and product weight raised to 25% after validation; AMLR review ceilings added |
Contents
- 1. Purpose, scope and legal basis
- 2. Customer segments and rating points
- 3. Risk factors and weights
- 4. Scoring model
- 5. Automatic triggers and prohibited relationships
- 6. Rating bands and due diligence levels
- 7. Worked examples
- 8. Overrides
- 9. Review frequency and re-rating
- 10. Data, lineage and quality
- 11. Governance, validation and performance monitoring
- 12. Glossary and references
- Standard and licence note
1. Purpose, scope and legal basis
The customer risk rating expresses, on one scale, how likely it is that a customer relationship is used for ML, TF, proliferation financing or sanctions evasion, given who the customer is, where it operates, what it uses and how it deals with the institution. The rating decides the due diligence level at onboarding, the approval authority, the maximum interval between periodic reviews, and the monitoring segment the customer falls into. It does not decide whether a suspicious activity report is filed; that decision always rests on the facts of a case.
Every customer of the entities in scope receives a rating, including customers onboarded before this methodology took effect. A customer shared between entities carries one group rating, the highest of the entity ratings.
| Jurisdiction (as of 2026-10, check local law) | Basis | What it requires in substance |
|---|---|---|
| FATF | R.1 Assessing risks and applying a risk-based approach; R.10 Customer due diligence | Apply CDD measures on a risk-sensitive basis |
| EU now | National law transposing Directive (EU) 2015/849 Art. 13 and Annexes I to III; EBA/GL/2021/02 | Consider risk variables and lower and higher risk factors when deciding the extent of CDD |
| EU from 2027-07-10 | AMLR Art. 20(2), Annexes I to III, Art. 26(2) | Individual risk analysis sets the extent of CDD; customer information updated at intervals not exceeding 1 year for EDD customers and 5 years for others |
| US (branch) | 31 CFR 1020.210(a)(2)(v)(A) | Understand the nature and purpose of the relationship to develop a customer risk profile |
| UK (if applicable) | MLR 2017, CDD and EDD regulations (regs 28 and 33) | Risk-sensitive CDD, considering the firm's own risk assessment |
2. Customer segments and rating points
The model uses two scorecards, because the information available and the relevant risks differ: one for natural persons (retail and private customers) and one for legal entities and arrangements (companies, partnerships, trusts, foundations, non-profit organisations). Financial institution respondents are not rated with this model; they are assessed with the Correspondent Banking Due Diligence (compliance/correspondent-banking-due-diligence) template under the correspondent methodology; respondents established outside the EU are High by default (TRG-03), and EU respondents take the rating that template produces.
| Segment | Scorecard | Customers at 2026-09-30 (Example) |
|---|---|---|
| Retail individuals | Natural persons | 400,000 |
| SME and commercial | Legal entities | 11,200 |
| Non-profit organisations, trusts and other | Legal entities | 500 |
| Financial institution respondents | Not scored; correspondent assessment | 300 |
| Corporate subtotal (legal entities and respondents) | 12,000 | |
| Total | 412,000 |
Check: 400,000 + 11,200 + 500 + 300 = 412,000 (400,000 retail and 12,000 corporate).
A rating is computed at the following rating points: at onboarding before the account is opened; at each periodic review; on any change to a scored data field (for example residence, ownership, industry, PEP status or products held); after an investigation closes with a finding of unusual activity; and when a new external list (high-risk third countries, sanctions, PEP data) changes a geography or screening outcome. The scoring engine records every rating with a timestamp, the input values and the methodology version, so any past rating can be reproduced.
3. Risk factors and weights
The model has four factor groups. Group weights reflect the business-wide risk assessment, where customer characteristics and product exposure drove most of the inherent risk, and the validation results described in section 11.
| Factor group | Weight | Rationale |
|---|---|---|
| Customer | 35% | Ownership opacity, PEP links and adverse media are the strongest predictors of SARs in the institution's own data |
| Geography | 25% | Cross-border exposure to higher-risk jurisdictions is a material inherent risk (BWRA area RA-04) |
| Product and service | 25% | Trade finance, correspondent and merchant services carry the highest inherent product risk (RA-02, RA-05) |
| Delivery channel | 15% | Remote onboarding risk is mitigated by electronic identification, so its weight is lower |
| Total | 100% |
Each factor value scores from 1 (lower risk) to 4 (higher risk). Within a group, sub-factors carry sub-weights that sum to 100% of the group.
3.1 Customer factor group
| Sub-factor | Scorecard | Sub-weight | Score 1 | Score 2 | Score 3 | Score 4 |
|---|---|---|---|---|---|---|
| Occupation and source of wealth | Natural persons | 40% | Salaried, verifiable income | Self-employed, standard sector | High-value or cash-intensive occupation; complex source of wealth | Source of wealth not plausibly explained (escalate) |
| PEP status | Natural persons | 30% | Not a PEP | Former domestic PEP outside the risk period set in the procedure | Domestic PEP, family member or close associate | Foreign PEP or international organisation PEP |
| Adverse media | Both | 30% (persons) / 20% (entities) | None | Old or minor, not related to financial crime | Credible allegations related to financial crime | Charges or convictions for predicate offences |
| Legal form and ownership complexity | Legal entities | 30% | Listed or regulated entity, or simple ownership | Two ownership layers | Three or more layers, or a trust or foundation in the chain | Nominee arrangements or bearer-share history |
| Industry | Legal entities | 30% | Low-risk sectors | Standard commercial | Sectors named in the national risk assessment, cash-intensive | Dual-use goods, precious metals and stones, arms (if permitted) |
| PEP connection (beneficial owners, directors) | Legal entities | 20% | None | Former domestic PEP | Domestic PEP | Foreign PEP |
3.2 Geography factor group
| Sub-factor | Sub-weight | Score 1 | Score 2 | Score 3 | Score 4 |
|---|---|---|---|---|---|
| Residence, nationality (persons) or incorporation and main place of business (entities) | 50% | Home countries and equivalent-standard jurisdictions | Other jurisdictions with no specific concerns | Jurisdictions with significant corruption, weak supervision or strategic deficiencies | High-risk third countries identified by the European Commission, or FATF call for action |
| Main counterparty countries (expected payment flows) | 50% | Domestic or EU | Other jurisdictions with no specific concerns | Any material flow to score-3 jurisdictions | Any flow to score-4 jurisdictions |
Country scores come from the country risk table maintained by the MLRO and refreshed after each list change and at least quarterly. The table records the source of each score.
3.3 Product and service factor group
The product score equals the highest score among the products and services the customer holds or applies for.
| Score | Products and services (Example) |
|---|---|
| 1 | Salary and savings accounts with domestic flows only; consumer loans; leasing |
| 2 | Current accounts with card and SEPA payments; instant payments; mortgages |
| 3 | International payments outside the EU; trade finance; private banking and investment accounts; merchant acquiring |
| 4 | Cash-intensive services such as large cash deposits or night safes; correspondent or payable-through services |
3.4 Delivery channel factor group
| Score | Channel (Example) |
|---|---|
| 1 | Face to face, identity verified in branch |
| 2 | Remote with qualified electronic identification or document and liveness verification |
| 3 | Through an introducer or intermediary |
| 4 | Remote without electronic identification where the law allows verification after onboarding |
4. Scoring model
The group score is the sub-weighted average of the sub-factor scores (or, for products and channels, the single score). The composite score is the weighted sum of the group scores.
Because every score lies between 1 and 4 and the weights sum to 1, the composite also lies between 1.00 and 4.00. Scores are computed and stored to two decimals; no rounding is applied before banding. A missing mandatory input does not default to a low score: the engine assigns the highest score for that sub-factor and raises a data quality task (section 10).
5. Automatic triggers and prohibited relationships
Automatic triggers apply before the composite score. A customer that meets any High trigger is rated High even if its composite score is lower; the score is still computed and stored for analysis. A customer that meets any prohibition is not onboarded, or is exited, in line with section 2 of the AML/CFT Programme Policy (compliance/aml-cft-programme-policy).
| Trigger ID | Condition | Result | Basis (summary) |
|---|---|---|---|
| TRG-01 (Example) | Customer, beneficial owner or authorised person is a PEP (domestic, foreign or international organisation), or a family member or known close associate of one (EU and UK). US branch: senior foreign political figure on a private banking account | High | FATF R.12; AMLD4 Arts 20 to 23; AMLR Arts 42 to 46; UK MLR reg. 35; 31 CFR 1010.620 |
| TRG-02 (Example) | Customer established in, or with a business relationship involving, a high-risk third country identified by the European Commission | High | FATF R.19; EU EDD rules |
| TRG-03 (Example) | Cross-border correspondent relationship with a respondent outside the EU | High | FATF R.13; EU EDD rules; US 31 CFR 1010.610 (EDD only for the 1010.610(c) categories; High for all third-country respondents is institution policy) |
| TRG-04 (Example) | Private banking account for a non-US person at the US branch | High | 31 CFR 1010.620 |
| TRG-05 (Example) | External SAR filed in the last 24 months and relationship retained | High | Institution policy |
| TRG-06 (Example) | Unresolved ownership structure after reasonable steps | High pending resolution; exit if unresolved within [60] days | Institution policy |
| PRH-01 to PRH-05 | Prohibited relationships in policy section 2 (shell banks, designated persons, anonymous accounts, unlicensed MVTS or CASPs, refusal to provide CDD information) | Decline or exit | Policy |
TRG-01 makes no distinction between domestic and foreign PEPs, because EU law (national law transposing AMLD4 now, the AMLR from 2027-07-10) and UK law require enhanced measures for every PEP, family member and known close associate. What differs is the extent of EDD, not whether it applies: national law and the AMLR define which domestic functions are prominent public functions (the national list under AMLR Art. 43), and for UK business MLR 2017 reg. 35(3A), inserted by SI 2023/1371 from 2024-01-10, sets a lower level of risk as the starting point for domestic PEPs and their family members and close associates, so their EDD is normally lighter than for a non-domestic PEP unless other enhanced risk factors are present. The PEP sub-factor scores in section 3.1 (3 for domestic, 4 for foreign) still feed the stored composite score, which the EDD analyst uses to size the measures. A former PEP stays under TRG-01 for at least 12 months after leaving office (AMLR Art. 45) and for as long afterwards as the risk persists.
6. Rating bands and due diligence levels
| Band | Composite score | CDD level | Onboarding approval | Maximum review interval | Monitoring segment |
|---|---|---|---|---|---|
| Low | 1.00 to 1.79 | Simplified due diligence where the law and risk assessment allow; otherwise standard | First line | 5 years | Standard |
| Medium | 1.80 to 2.59 | Standard CDD | First line with KYC quality assurance | 3 years | Standard |
| High | 2.60 to 4.00, or any High trigger | Enhanced due diligence (EDD Memo (compliance/edd-memo)) | Senior manager plus MLRO or delegate | 1 year | Enhanced, lower thresholds |
The 5-year and 1-year intervals are the AMLR ceilings that apply from 2027-07-10 for customers not subject to EDD and for EDD customers respectively; the 3-year interval for Medium is the institution's own choice. Shorter intervals required by national law prevail.
Portfolio distribution at 2026-09-30 (Example):
| Band | Customers | Share |
|---|---|---|
| Low | 338,000 | 82.0% |
| Medium | 64,000 | 15.5% |
| High | 10,000 | 2.4% |
| Total | 412,000 | 100% (shares rounded) |
Of the 10,000 High customers, 3,600 are High through an automatic trigger and 6,400 through the composite score (3,600 + 6,400 = 10,000).
7. Worked examples
All examples are fictional and use the weights in section 3.
CUS-EX-01 (Example): SME importer of industrial parts, three ownership layers including a family trust, suppliers in score-3 jurisdictions, uses trade finance, onboarded in branch.
| Group | Sub-factor scores and sub-weights | Group score | Weight | Contribution |
|---|---|---|---|---|
| Customer | Ownership 3 x 0.30; industry 3 x 0.30; PEP connection 1 x 0.20; adverse media 1 x 0.20 | 0.90 + 0.90 + 0.20 + 0.20 = 2.20 | 0.35 | 0.770 |
| Geography | Incorporation 1 x 0.50; counterparties 3 x 0.50 | 0.50 + 1.50 = 2.00 | 0.25 | 0.500 |
| Product | Trade finance = 3 | 3.00 | 0.25 | 0.750 |
| Channel | Face to face = 1 | 1.00 | 0.15 | 0.150 |
| Composite | 2.17, Medium |
Record the reasoning for each sub-factor score in the KYC profile (here: a trust sits in the ownership chain, so ownership scores 3), so that a reviewer can check the score without re-running the engine.
CUS-EX-02 (Example): non-resident individual, foreign PEP, complex source of wealth, investment account, onboarded remotely with electronic identification.
| Group | Sub-factor scores and sub-weights | Group score | Weight | Contribution |
|---|---|---|---|---|
| Customer | Occupation and source of wealth 3 x 0.40; PEP 4 x 0.30; adverse media 1 x 0.30 | 1.20 + 1.20 + 0.30 = 2.70 | 0.35 | 0.945 |
| Geography | Residence 3 x 0.50; counterparties 2 x 0.50 | 1.50 + 1.00 = 2.50 | 0.25 | 0.625 |
| Product | Investment account = 3 | 3.00 | 0.25 | 0.750 |
| Channel | Remote with electronic identification = 2 | 2.00 | 0.15 | 0.300 |
| Composite | 2.62, High (TRG-01 also applies) |
CUS-EX-03 (Example): domestic salaried individual, salary account and card, onboarded through the app.
| Group | Sub-factor scores and sub-weights | Group score | Weight | Contribution |
|---|---|---|---|---|
| Customer | 1 x 0.40; 1 x 0.30; 1 x 0.30 | 1.00 | 0.35 | 0.350 |
| Geography | 1 x 0.50; 1 x 0.50 | 1.00 | 0.25 | 0.250 |
| Product | Salary account = 1 | 1.00 | 0.25 | 0.250 |
| Channel | Remote with electronic identification = 2 | 2.00 | 0.15 | 0.300 |
| Composite | 1.15, Low |
CUS-EX-04 (Example): small domestic retailer, simple ownership, standard sector, current account, onboarded in branch; later upgraded by override (section 8).
| Group | Sub-factor scores and sub-weights | Group score | Weight | Contribution |
|---|---|---|---|---|
| Customer | Ownership 2 x 0.30; industry 2 x 0.30; PEP connection 1 x 0.20; adverse media 1 x 0.20 | 0.60 + 0.60 + 0.20 + 0.20 = 1.60 | 0.35 | 0.560 |
| Geography | 1 x 0.50; 1 x 0.50 | 1.00 | 0.25 | 0.250 |
| Product | Current account = 2 | 2.00 | 0.25 | 0.500 |
| Channel | Face to face = 1 | 1.00 | 0.15 | 0.150 |
| Composite | 1.46, Low; overridden to Medium (OVR-2026-0412) |
8. Overrides
An analyst may propose an override when facts known to the institution are not captured by the scorecard, for example unexplained cash deposits, an internal investigation outcome, or information from a law-enforcement request. Every override records the reason, the evidence, the proposer, the approver and an expiry date, after which the computed rating applies again unless the override is renewed.
| Override type | Who may propose | Who approves | Maximum duration | Restrictions |
|---|---|---|---|---|
| Upgrade by one or more bands | Any KYC analyst, investigator or relationship manager | KYC team lead | Until next periodic review | None |
| Downgrade by one band | KYC analyst | MLRO or deputy MLRO | [12] months | Not allowed for automatic triggers TRG-01 to TRG-05 |
| Downgrade by two bands | Not permitted | Not applicable | Not applicable | Not applicable |
| Override ID | Customer | Computed | Final | Reason | Approver | Expiry |
|---|---|---|---|---|---|---|
| OVR-2026-0412 (Example) | CUS-EX-04 | Low (1.46) | Medium | Cash deposits three times the expected monthly turnover, explained only in part | [@kyc-team-lead] | Next periodic review |
The MLRO monitors the override rate monthly. In the 12 months to 2026-09-30, 1,240 overrides were recorded (0.30% of 412,000 customers), of which 85 were downgrades (Example). A downgrade share above [10%] of overrides, or any concentration of downgrades in one business line, triggers a review by the second line.
9. Review frequency and re-rating
Each periodic review refreshes the customer information, re-runs screening and recomputes the rating with the current methodology version. The review date is set from the band in section 6 and counts from the completion of the previous review, never from the original onboarding date. When the methodology changes, customers whose rating moves up are reviewed within [90] days; customers whose rating moves down keep their current review date.
Event-driven reviews start within [10] business days when any of the following occurs: a change to a scored data field; a confirmed adverse media hit; an investigation closed with a finding; a law-enforcement request; a new designation affecting the customer or a related party; or a change in a country score that affects the customer. From 2027-07-10, the AMLR also expects updates when the institution has a legal obligation to contact the customer about beneficial ownership information or tax information exchange, and regular checks against targeted financial sanctions on each new designation for credit and financial institutions.
Overdue reviews of High customers are a board risk appetite metric (Risk Appetite Statement (finance/risk-appetite-statement), RAS-CMP-01: appetite 2.0%, tolerance 4.0%; actual 2.9% at 2026-09-30, amber (Example)). At 10,000 High customers, the 2.9% figure means 290 overdue reviews (10,000 x 0.029 = 290).
10. Data, lineage and quality
The rating can only be as good as its inputs. Each input field has a named data owner, an authoritative source and a quality rule. The scoring engine reconciles its customer population with the core banking and KYC systems monthly, and every unrated or partially rated customer is reported as an exception.
| Input | Source system | Owner | Quality rule | Default if missing |
|---|---|---|---|---|
| Residence / incorporation country | KYC platform | Head of KYC | ISO 3166 code, mandatory | Score 4 and data task |
| Industry | KYC platform (NACE code) | Head of KYC | Valid NACE code, mandatory for entities | Score 4 and data task |
| Ownership layers | Beneficial ownership module | Head of KYC | Structure chart complete | Score 4 and TRG-06 |
| PEP status | Screening system | Head of sanctions and screening | Screening within 24 hours of change | Score 4 until screened |
| Adverse media | Screening system | Head of sanctions and screening | Confirmed hits only | Score 1 only where screening ran with no confirmed hit; if screening has not run, Score 4 and data task |
| Products held | Core banking | Head of operations | Daily feed | Highest product score in segment |
| Onboarding channel | Onboarding platform | Head of digital | Mandatory at account opening | Score 4 |
| Counterparty countries | Payments data warehouse | Head of FCC analytics | 12-month rolling window | Expected flows from KYC profile |
| Data quality indicator | Value at 2026-09-30 (Example) | Threshold |
|---|---|---|
| Customers without a rating | 0 | 0 |
| Customers with at least one defaulted input | 1,850 (0.45%) | Below 1.0% |
| Population reconciliation breaks | 12 | Below 50, all explained |
Check: 1,850 / 412,000 = 0.45%.
11. Governance, validation and performance monitoring
The methodology is owned by the MLRO. Where it is implemented in an automated engine, it is registered in the model inventory and managed under the Model Risk Management Policy (finance/model-risk-management-policy). Independent validation covers conceptual soundness (are the factors and weights justified by the risk assessment and the risk factor guidance?), implementation (does the engine compute what the document says?), data (are inputs complete and correct?) and outcomes (does the rating separate higher-risk from lower-risk customers?). Validation results are documented in the Model Validation Report (ai-data/model-validation-report).
Outcome analysis compares ratings with later evidence of risk, such as external SARs, exits for financial crime reasons and confirmed sanctions matches. A useful rating shows a steeply rising rate of such outcomes from Low to High.
| Band | Customers | External SARs, 12 months | Share of SARs | SARs per 1,000 customers |
|---|---|---|---|---|
| Low (Example) | 338,000 | 110 | 18.0% | 0.33 |
| Medium (Example) | 64,000 | 226 | 37.0% | 3.53 |
| High (Example) | 10,000 | 274 | 44.9% | 27.40 |
| Total (Example) | 412,000 | 610 | 100% (rounded) | 1.48 |
Check: 110 + 226 + 274 = 610 SARs, matching the business-wide risk assessment. Rates: 110 / 338 = 0.33, 226 / 64 = 3.53, 274 / 10 = 27.40 and 610 / 412 = 1.48 per 1,000 customers. The rate rises roughly eight- to elevenfold from band to band (3.53 / 0.33 = 10.7; 27.40 / 3.53 = 7.8), which supports the band boundaries. A Low band that produced a growing share of SARs would show that a risk is not captured by the factors and would trigger a methodology review.
| Monitoring metric | Frequency | Trigger for review (Example) |
|---|---|---|
| Band distribution by segment | Monthly | Shift of more than 2 percentage points in a quarter without a known cause |
| SAR rate by band | Quarterly | Low band SAR share above 25% |
| Override rate and downgrade share | Monthly | Downgrades above 10% of overrides |
| Defaulted inputs | Monthly | Above 1.0% of customers |
| Sensitivity to weight changes | At each methodology change | More than 5% of customers change band after a weight change of 5 points |
Methodology changes follow change control: the MLRO proposes, model risk management reviews, the engine change is tested on a full-portfolio parallel run, and the change is approved before deployment. The parallel run reports how many customers move between bands and why. Version 2.0 (Example) moved 2,300 customers from Medium to High and 900 from High to Medium; the High-to-Medium moves were reviewed by the MLRO before the change took effect.
12. Glossary and references
| Term | Meaning |
|---|---|
| Composite score () | Weighted sum of group scores, 1.00 to 4.00 |
| Group score () | Sub-weighted average of the sub-factor scores in one factor group |
| Automatic trigger | Fact that sets the rating to High regardless of score |
| Override | Documented, approved change of the computed rating |
| CDD / EDD / SDD | Customer, enhanced and simplified due diligence |
| PEP | Politically exposed person |
| Rating point | Moment at which the rating is computed |
References (obtain the current official versions):
- FATF Recommendations, R.1 Assessing risks and applying a risk-based approach; R.10 Customer due diligence; R.12, R.13, R.19 (number and title only).
- Directive (EU) 2015/849, Art. 13, Arts 20 to 23 (PEPs) and Annexes I to III, as amended and transposed; EUR-Lex.
- Regulation (EU) 2024/1624 (AMLR), Art. 20(2), Art. 26, Arts 42 to 46 (PEPs), Annexes I to III; applies from 2027-07-10; EUR-Lex.
- EBA Guidelines on ML/TF risk factors, EBA/GL/2021/02, as amended.
- 31 CFR 1020.210(a)(2)(v), 1010.610, 1010.620; FFIEC BSA/AML Examination Manual.
- UK MLR 2017 (SI 2017/692), regs 28, 33 and 35, as amended by SI 2023/1371 (domestic PEPs, in force 2024-01-10).
- Related templates: KYC/CDD Customer Profile (
compliance/kyc-cdd-profile), Transaction Monitoring Scenario Specification (compliance/transaction-monitoring-scenario-spec), Risk Methodology (compliance/risk-methodology).
Standard and licence note
Based on public law: EU legislation from EUR-Lex (Directive (EU) 2015/849 and Regulation (EU) 2024/1624), reused with acknowledgement and summarised in original wording; US federal regulations in 31 CFR Chapter X and FFIEC publications (US government works, public domain); and the UK Money Laundering Regulations 2017 (Crown copyright, Open Government Licence v3.0 where stated). The EBA risk factor guidelines are cited by number with acknowledgement and no text is reproduced. FATF Recommendations are cited by number and title only. The factors, weights, bands and scores are original and illustrative; they are not regulatory requirements. Fernhollow Bank and all figures are fictional. This template is original text written for this collection. Check the current official version of each law and guideline before use. Template licence: MIT.
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