Read our response to EBA's consultation to the proposed changes to the Risk Factor Guidelines
We consider and assess the proposed changes to the EBA's Risk Factor Guidelines and provide guidance on how organisations should best reflect and operationalise these changes in their AML/CFT procedures and processes.
In this paper we provide recommendations and insightful commentary on:
- Risk assessment and risk appetite
- Ongoing Customer Due Diligence ("CDD") and tax "triggers"
- The approach to registers in relation to Beneficial Owners and Controllers
- Golden visa schemes
- High Risk Third Countries ("HRTCs") and jurisdictional links