The AML Risk Assessment Matrix is a mandatory compliance tool required under Irish AML/CFT legislation and EU directives. It is designed to help organizations systematically evaluate their exposure to money laundering and terrorist financing risks. The document must be maintained by regulated entities operating in Ireland to demonstrate compliance with the Criminal Justice (Money Laundering and Terrorist Financing) Act 2021 and related regulations. The matrix should be reviewed and updated regularly to reflect changes in the business environment, regulatory requirements, and emerging risks. It serves as a foundation for implementing risk-based approaches to AML/CFT compliance and helps organizations allocate their compliance resources effectively based on identified risk levels.
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1. Introduction and Purpose: Overview of the risk assessment matrix purpose, regulatory context, and how the document should be used
2. Scope and Applicability: Definition of the assessment's scope, including business areas, products, and services covered
3. Risk Assessment Methodology: Detailed explanation of the risk scoring system, risk categories, and assessment criteria
4. Customer Risk Factors: Assessment of risks related to customer types, including PEPs, high-risk jurisdictions, and complex ownership structures
5. Geographic Risk Factors: Evaluation of country and jurisdiction risks, including sanctions lists and high-risk territories
6. Product and Service Risk Factors: Analysis of risks associated with different products and services offered
7. Distribution Channel Risk Factors: Assessment of risks related to delivery channels and payment methods
8. Risk Scoring and Classification: Methodology for combining risk factors and determining overall risk ratings
9. Control Measures and Mitigation: Description of controls and measures to mitigate identified risks
10. Review and Update Procedures: Processes for periodic review and updating of the risk assessment
1. Virtual Asset Service Provider Risks: Include when the organization deals with virtual assets or cryptocurrencies
2. Correspondent Banking Risks: Include for financial institutions engaged in correspondent banking relationships
3. Trade Finance Risks: Include when the organization provides trade finance services
4. Private Banking Risks: Include when offering private banking or wealth management services
5. Industry-Specific Risk Factors: Include sector-specific risks relevant to the organization's primary business activities
1. Schedule 1: Risk Factor Scoring Tables: Detailed scoring matrices for each risk factor category
2. Schedule 2: High-Risk Countries List: Current list of high-risk jurisdictions and associated risk levels
3. Schedule 3: Customer Risk Classification Guide: Detailed guidance for classifying customer risk levels
4. Appendix A: Regulatory References: List of relevant regulations and guidance documents
5. Appendix B: Risk Assessment Templates: Standard templates for conducting risk assessments
6. Appendix C: Control Effectiveness Matrix: Framework for evaluating the effectiveness of control measures
Authors
Relevant legal definitions
Clauses
Relevant Industries
Banking
Insurance
Investment Services
Credit Unions
Payment Services
Virtual Asset Service Providers
Legal Services
Accounting Services
Real Estate
Gaming and Gambling
Retail Banking
Corporate Banking
Investment Management
Fintech
Relevant Teams
Compliance
Risk Management
Legal
Internal Audit
Operations
Customer Due Diligence
Financial Crime Prevention
Regulatory Reporting
Business Development
Product Development
Customer Onboarding
Transaction Monitoring
Relevant Roles
Chief Compliance Officer
AML Officer
Money Laundering Reporting Officer (MLRO)
Risk Manager
Compliance Analyst
Internal Auditor
Chief Risk Officer
Regulatory Compliance Manager
Financial Crime Specialist
Due Diligence Officer
Legal Counsel
Chief Executive Officer
Board Member
Operations Director
Business Unit Head
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