Assessing and Managing Risks
16 free CySEC AML Chapter 5 flashcards. Tap a card to flip, or use the arrow keys to move through the deck.
Card 1 of 16Risk-based approach
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Know the numbers? Now learn the why.Read the AML Risk Assessment study notes: short answers, key numbers and the law behind each rule.
- What is the risk-based approach to AML, and how do firms identify their risks?
- What are the main ML/TF risk factors, and what makes a customer higher risk?
- How do firms assess country and geographical risk?
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Risk-based approach
- What does the risk-based approach require?
- Effort proportionate to the nature and size of the firm, concentrating controls and resources where ML/TF risk is highest.
- Which authority leads AML/CFT coordination and the Risk Factors Guidelines from 1 January 2020?
- The EBA (European Banking Authority), until the end of 2025. On 1 January 2026 the EU Anti-Money Laundering Authority (AMLA) took over; the EBA guidelines stay in force until AMLA replaces them.
Risk assessment
- What are the two steps of assessing ML/TF risk?
- First identify the risks the firm is exposed to, then assess their level — both are needed.
- How current must the firm's risk assessment be?
- Updated and under ongoing review — risk is not static, so controls must keep fitting the actual level of ML/TF risk.
Risk factors
- What are the four categories of AML risk factor?
- Customer, country/geography, product/service/transaction, and delivery channel.
Risk levels
- What are the three standard risk levels and their CDD responses?
- High (EDD + enhanced monitoring), medium/normal (standard CDD under Article 61(1)), and low (SDD).
Mandatory high risk
- Which situations are mandatorily high-risk by law?
- A PEP customer or beneficial owner, and a link to a high-risk third country; EDD applies regardless of the firm's own score. Exam material: a customer based in a high-risk third country. Since 23 February 2021: any business relationship or transaction involving one, wherever the customer is based.
SDD / EDD
- Does simplified due diligence remove CDD?
- No — SDD adjusts the amount, timing or type of CDD to fit low risk, but never removes it entirely.
Delivery channel
- What is the main driver of delivery-channel risk?
- Distance — non-face-to-face onboarding, and the use of introducers or intermediaries.
Record-keeping
- What is the baseline record-retention period, and how far can it extend?
- 5 years after the end of the relationship or occasional transaction, extendable by up to a further 5 years (10 total) where justified for ML/TF purposes.
Monitoring
- Which article requires ongoing transaction monitoring?
- Article 61(1)(d) of the AML/CFT Law.
Weighting
- What makes a risk-weighting methodology sound?
- No single factor disproportionately dominates, profit must not influence the rating, and the model must always be capable of producing a high-risk result.
Geography
- Which geographies are higher-risk?
- Sanctioned countries, those with strategic AML/CFT deficiencies, significant corruption, or terrorist links.
Records access
- When must records be produced to the Unit or Supervisory Authority?
- Upon request and without delay.
EDD
- Is EDD a replacement for regular CDD?
- No — EDD is always applied in addition to normal CDD, never as a substitute.
Customer risk
- On what does customer risk turn?
- The customer's activity, reputation, and nature/behaviour — for example demands for unnecessary secrecy or unexplained wealth raise risk.