T07 Risk assessment form – entity
Client name File No. Ref.
Prepared by Date
Does the client meet the requirement for automatic Enhanced Y N
Due Diligence (EDD)bas a result of:
Being a case identified as high risk in our firm-wide risk
assessment.
Transactions being conducted on behalf of a politically exposed
person (PEP) or a close family member or known close associate of
a PEP. Beneficial owner is a PEP, close family member of a PEP
or know close associate of a PEP.
Providing false or stolen ID documentation.
Transactions being complex and unusually large or having an
unusual pattern of transactions.
Being in a business relationship or transaction with a person
established in a high risk third country.
The transaction/(s) having no apparent economic or legal purpose.
Any ‘yes’ answers will indicate a high risk client for AML purposes Yes
High Risk
No
Are any of the following risk factors present in your client? Y N
The business relationship is conducted in unusual circumstances.
The customer is resident in, or has connections to, a geographical
area of higher risk.
The business is cash intensive.
The entity is involved in transactions that favour anonymity.
The entity’s structure is unusual or excessively complex.
You have not met a senior representative of the client.
The entity receives payments from unknown or un-associated third
parties.
Does the presence of any of these risk factors indicate a Yes
higher risk of money laundering or terrorist financing? The High Risk
presence of these factors may indicate a high risk for AML
purposes but will not automatically do so.
No
See next page
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T07 Risk assessment form – entity
Does the individual otherwise present a higher than normal risk of money Yes
laundering or terrorist financing? High Risk
No
Does the client meet the criteria for simplified due diligence Y N
as a result of:
There being a very low risk of money laundering or terrorist
financing due the nature of the entity, the services provided and
is located in a geographical area of lower risk as provided for in
the Anti-Money Laundering and Counter-Terrorist Financing
Ordinance (Cap. 615)/ AML/CTF Guidelines issued by the
HKICPA
It is a public administration, or a publicly owned enterprise;
It is a company whose securities are listed on a regulated
market, and subject to disclosure requirements regarding
ownership.
Any ‘yes’ answers may indicate a low risk client for AML purposes but will not Yes
automatically do so. Low risk
No
Normal Risk
Enhanced due diligence to be performed where risk is assessed as high Y N N/A
Obtaining approval of senior management to commence or continue the
relationship
Additional evidence to support verification of identity
More detailed customer due diligence/ Know Your Client information to better
understand the background, ownership and financial situation of the client and
others party to transactions
Additional steps to be satisfied that transactions are consistent with the purpose
and intended nature of the business relationship
Increased monitoring of the business relationship
Increased scrutiny of transactions
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