The Semi-Annual AML Return on Risk Based Approach focuses on the drilling through the Institutions Customer Base, assessing the level of risk attached to the customer profiles.
The first part of the report requires an analysis of Loans and Deposits, broken down by a number of different attributes such as:
- For Legal Entities
- When the Resident Country of the Ultimate Beneficial Owner does not comply with the FATF-GAFI AML Compliance Standards, or is a resident in other High Risk country
- Ultimate Beneficial Owners resident in non-EU Countries
- Classified as Bearer-Shares entities
- Classified as Trusts / Foundations
- For Individuals
- Non face-to-face customers
- Residents in countries which do not comply with the FATF-GAFI AML Compliance Standards, or are residents in other High Risk countries
- Residents in non-EU Countries
- Defined as Politically Exposed Persons (PEPs)
- Classified as Vulnerable to Tax Evasion
- Client Accounts (i.e. pool accounts handled by brokerage / insurance firms, payment institutions, lawyers, accounting firms, etc.)
Information on Wire Transfers, Cash Transactions, Private Banking and Correspondent Accounts are also required.
The Second Part of the Return drills further into customer related quality and risk profile data.