Firm-Wide
ML/TF/PF Firm Wide Risk Assessment (FWRA)
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations, 2017, also commonly known as MLR 17, requires regulated businesses to carry out ML, TF, and PF Firm-Wide Risk Assessment (FWRA). ML, TF, and PF Firm-Wide Risk Assessment is also known as Business-Wide Risk Assessment, Enterprise-Wide Risk Assessment, Financial Crime Risk Assessment, or ML/FT and PF Risk Assessment. Business-Wide Risk Assessment is the foundation of the risk-based approach (RBA) as recommended by the Financial Action Task Force (FATF) and is central to having an adequate and appropriate AML compliance strategy.
The AML Policy, procedures, systems, and controls have to be aligned and proportionate to the business-wide risk assessment. The higher the risk, the higher the control measures need to be; this is the basic requirement of a risk-based approach, that a Firm-Wide Risk Assessment help you achieve.
ML, TF, and PF Firm-Wide Risk Assessment Methodology
AML Consultants UK take into account the UK National Risk Assessment, the EU Supra-National Risk Assessment, findings of FATF, the input of the AML Compliance Officer and the Nominated Officer, and the nature and size of individual businesses to perform customised Business Risk Assessment.
AML Consultants UK then identify the risk factors and their likelihood and impact to identify areas to be prioritised in terms of AML/CTF and CPF and the policies, controls, and procedures to be designed and implemented to keep those risks below the risk appetite.
Business-Wide Risk Assessment (BWRA) Process Steps
Risk Identification
- Customers
- Countries
- Delivery channels
- Products, services, transactions
- Staff, third parties
Risk Analysis
- Likelihood of risk materialisation
- Impact: effects of risk materialisation
Risk Control
- Policies and Procedures
- Systems and Controls
Risk Monitoring and Review
- Review of risk analysis
- Compliance and audit programs
The business risk assessment is a cyclical process of identifying, assessing, analysing, upgrading, and fine-tuning controls’ effectiveness.
Risk Assessment. Risk Management. Compliant.
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FWRA Steps
Overview of the Business
We make an overview of the business with respect to products, customers, countries, staff, third parties
Identify Risk Scenarios
We assess which money laundering, terrorism financing, and proliferation financing risks may occur and how they may materialise.
Analysis of ML/FT/PF Scenarios
We determine the likelihood of each of the probable risk scenario materialising and resulting impact.
Analysis of Controls
AML Consultants assess the control measures in place for each ML/FT/PF scenario.
Determination Of Residual Risks
We determine the residual risk for each ML/FT/PF scenario by comparing inherent risk and the level of control.
Assess Risk Appetite
We verify whether the risk is within the boundaries of the risk appetite.
Determine Additional Measures
AML Consultants determine the type of action to be taken to increase control or reduce risk
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How Can
AML Consultants UK Help?
AML Consultants UK help businesses and professionals carry out their business risk assessment and determine the measures to control the ML/FT and PF risks. It helps businesses to identify inherent risks arising out of merely being in the business and residual risks after the application of risk mitigation measures related to products, services, customers, delivery channels, and geographies. The businesses can become aware of their ML/FT and PF risk exposure, formulate and implement appropriate policies and controls to mitigate such risks and keep them within the limits of their risk appetite.
