Michael Parkes Chartered Surveyors - Money Laundering Risk Assessment Form
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2MONEY LAUNDERING RISK ASSESSMENT FORM
The factors posed below should be considered when assessing the risk of the client and/or the transaction. Please use the notes column to summarise
observations/assessment of risks involved where the issue is applicable to the client/transaction being considered. Not all questions will be relevant
or applicable to all situations. Conversely, the questions outlined are non-exhaustive– there may be other pertinent risk factors which should be
taken into account, dependent upon the nature of the client/transaction being considered.
CLIENT RISK
NOTES
STATUS OF CLIENT
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Is your client known to you personally/existing client, or new business relationship?
•
rd
Has your client been introduced to you by a 3
Party? Is S.17 reliance being used?
•
rd
Is the instruction from your client channelled through a 3
party? If so, why?
•
Is your client a politically exposed person?
•
If your client is not a natural person but rather a legal entity, do you have full visibility
and ID&V of beneficial owners and directors / controllers?
FACE TO FACE CONTACT
•
Have you met with your client face to face or is it a non-face to face transaction?
•
If non-face to face, are you comfortable there is a legitimate reason for this?
LOCATION OF CLIENT
•
Where is your client based? Locally /UK/EU/other international location?
•
Are you aware of your client having any links to criminality?
•
Is your client based in a high-risk jurisdiction or resident in/links to a sanctioned
country?
ID & ADDRESS VERIFICATION
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Has your client provided acceptable standard ID and address verification?
•
Has your client provided acceptable non-standard ID and address verification?
•
If using s.17 reliance (obtaining certified copies of ID & address verification), have you
been able to confirm the authenticity/professional status of the certifier?
•
Has your client been cooperative in the process or have they delayed providing ID and
address verification / appeared reluctant to do so?
FINANCIAL PROFILE OF CLIENT
•
Does the stated source of wealth / source of funds and the amount of money involved
stack up with what you know of your client, for example given their age and occupation?
(evidence of SoW required in high risk clients/transactions)
•
Is your client involved in / run a high risk or high cash turnover business?
TRANSACTION RISK
NOTES
TRANSACTION TYPE
•
Could the type of transaction be used for the purposes of money laundering or is it at
a higher risk of money laundering?
- Eg, Will / Power of Attorney - lower risk
- Estate Agency / Conveyancing / Commercial Property - higher risk
•
Does the transaction make sense or is it overly complex given the underlying nature of
the business being conducted?
•
Does it make sense that your client has asked your firm to carry out this type of
transaction? (e.g. is it within your area of expertise/local geographical area?)
VALUE OF TRANSACTION
•
Does the value of the transaction appear to fall within the financial means of your
client, given their income and savings?
SOURCE OF FUNDS
•
Is the source of funds clear and identifiable?
•
Are funds coming from a recognised financial/credit institution or are they personal
funds?
•
Is any funding coming from overseas? Where from? Who from? Connection to client?
•
Are any of the funds being paid by a third party otherwise unconnected to the
transaction?
•
Does your client seek to change the source of funds at the last minute?
•
Has your client paid excess funds into your client account? Why/How?
DESTINATION OF FUNDS
•
Has your client requested that free proceeds be paid to someone other than a lender
or themselves?
•
Are free proceeds to be paid to an overseas account?
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