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The Business-Wide Risk Assessment Explained

The business-wide risk assessment is the foundation of every regulated firm’s anti-money laundering framework. It sets out how the firm could be used to launder money or finance terrorism, and it drives everything that follows: customer due diligence standards, transaction monitoring, staff training and the resources the financial crime function needs. It is also one of the first documents a supervisor asks for, and one of the most common sources of findings when it is generic, out of date or disconnected from the firm’s actual controls. This guide explains what the Money Laundering Regulations require, how a good assessment is built, and who should own it.

What the Regulations Require

Regulation 18 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 requires a firm to take appropriate steps to identify and assess the risks of money laundering and terrorist financing to which its business is subject. In doing so, it must take into account information made available by its supervisor and risk factors relating to:

  • its customers;
  • the countries or geographic areas in which it operates;
  • its products or services;
  • its transactions; and
  • its delivery channels.

The steps must be proportionate to the size and nature of the business. The assessment must be recorded in writing, kept up to date, and provided to the supervisor on request. Regulation 19 then requires the firm to establish and maintain policies, controls and procedures to mitigate and manage effectively the risks identified, again proportionate to the business and approved by senior management.

For FCA-regulated firms, the FCA’s rules in SYSC 6.3 add the expectation of regular assessment of the adequacy of the firm’s systems and controls, and the FCA’s Financial Crime Guide sets out what good practice looks like. Industry guidance from the Joint Money Laundering Steering Group covers the risk-based approach in detail, with sector-specific chapters. Our overview of the Money Laundering Regulations 2017 puts regulation 18 in the context of the wider framework.

Business-Wide vs Customer Risk Assessment

Two kinds of risk assessment are often confused. The business-wide assessment looks at the firm as a whole. The customer risk assessment looks at each individual customer and decides what level of due diligence and monitoring they need. The two are connected: the business-wide assessment sets the framework, including the risk factors and weightings, that the customer risk assessment applies.

Business-wide risk assessmentCustomer risk assessment
Legal basisMLR regulation 18MLR regulation 28(12) and (13), plus enhanced due diligence rules
ScopeThe whole firm: customer base, geographies, products, transactions, channelsAn individual customer or business relationship
OutputInherent and residual risk ratings; the control framework; resourcingA risk rating that sets due diligence and monitoring levels
OwnerUsually the MLRO, approved by the board or senior managementFront line or onboarding team, applying the firm’s methodology
FrequencyAt least annually and on material changeAt onboarding and on review or trigger events

Our guide to customer due diligence and enhanced due diligence covers the customer level.

Sources the Assessment Should Draw On

A credible assessment is grounded in evidence, not just the assessor’s view. The main sources are:

  • the UK’s National Risk Assessment of money laundering and terrorist financing, which sets out the government’s view of the highest-risk sectors and methods
  • information published by the FCA as supervisor, including thematic reviews, Dear CEO letters, the Financial Crime Guide and enforcement notices
  • JMLSG guidance, including the sector chapters relevant to the firm
  • lists of high-risk third countries and sanctions regimes
  • the firm’s own data: customer profiles, products, volumes, transaction patterns, geographies and channels
  • the firm’s own experience: internal suspicion reports, SARs, fraud cases, audit findings and near misses

The last two are where many assessments fall short. A document built only on published sources describes a generic firm, not this one.

A Practical Methodology

There is no prescribed method, but most good assessments follow the same broad structure:

  • Map the business. List the firm’s customer types, products and services, geographies, transaction types and delivery channels, with volumes and values where possible.
  • Assess inherent risk. For each area, assess how attractive and vulnerable it is to money laundering and terrorist financing before controls, using the external and internal sources above.
  • Assess controls. Identify the controls that mitigate each risk, such as due diligence, screening, monitoring and training, and assess how well they are designed and how effectively they operate in practice.
  • Determine residual risk. Combine inherent risk and control effectiveness into a residual rating for each area and for the firm overall.
  • Set actions. Where residual risk is above the firm’s appetite, record the actions needed, with owners and deadlines.
  • Link to the customer methodology. Make sure the customer risk assessment uses the same risk factors and reflects the conclusions.
  • Approve and communicate. Present the assessment to senior management or the board for approval, and share relevant conclusions with the business.

Scoring matrices are common and useful, but they are not a substitute for judgement. Supervisors want to see the reasoning behind each rating, not just the numbers.

How the Assessment Drives Controls

The business-wide assessment only has value if it changes what the firm does. Each conclusion should flow through to the control framework:

Assessment conclusionControl it should drive
Higher risk from certain customer types or jurisdictionsEnhanced due diligence triggers and approval requirements
Higher risk in particular products or transaction typesSpecific transaction monitoring scenarios and thresholds
Exposure to sanctions through cross-border flowsScreening coverage and ownership and control checks
Non-face-to-face onboarding riskIdentity verification and fraud controls
Third-party or introducer riskOversight and reliance arrangements
Rising volumes or new risksAdditional resources in the financial crime team

Our guides to transaction monitoring and sanctions screening explain how those controls should reflect the risk assessment. Resourcing is part of the same chain: our guide to sizing the financial crime team at a payments or e-money firm shows how risk and volume drive headcount.

When to Refresh It

The Regulations require the assessment to be kept up to date. In practice, most firms review it at least annually, and also when something material changes. Typical triggers include:

  • launching a new product, service or delivery channel;
  • entering a new market or taking on a new customer segment;
  • a significant change in volumes or transaction patterns;
  • an acquisition or major change in business model;
  • a new National Risk Assessment, sanctions development or significant supervisory publication; and
  • audit findings, enforcement action in the sector, or a material financial crime incident at the firm.

A risk assessment that is reviewed only on its anniversary, while the business has changed around it, is one of the most common findings supervisors make.

Who Owns It

The MLRO, approved as SMF17 at firms within the SMCR, normally owns the business-wide risk assessment. It is the central document in their oversight of the firm’s anti-money laundering systems and controls, and it underpins the annual MLRO report to the board. In larger firms, a deputy MLRO or financial crime team may prepare much of the analysis, and first-line business areas contribute their own data and views. But the MLRO should own the conclusions and be able to defend them to a supervisor.

Senior management, usually the board, must approve the policies and controls that follow from the assessment, and in practice should approve or at least review the assessment itself. Boards should challenge it: does it reflect the business as they understand it, and are the actions being delivered?

Ownership of the assessment is one reason the MLRO appointment matters so much. An MLRO who can build an evidence-based, firm-specific assessment is far more valuable than one who updates a template. Our page on MLRO recruitment (SMF17) covers what to look for, and for smaller firms where one person holds both functions, our page on combined compliance officer and MLRO recruitment applies.

Scenario: A small authorised payment institution’s business-wide risk assessment was written by consultants for its authorisation application. Two years later, the firm has added merchant acquiring for online businesses, many outside the UK, but the assessment still describes a domestic consumer remittance business. Its monitoring scenarios reflect the original model, and merchant risk isn’t assessed at all. When its banking partner asks for the current assessment, the gap is obvious. The firm’s fractional MLRO rebuilds the assessment around the actual business, adds merchant risk factors to the customer methodology, introduces new monitoring scenarios for merchant activity, and asks the board for an additional analyst. The board approves the revised assessment and sets a six-monthly review while the business is growing.

Common Weaknesses Supervisors Find

  • generic assessments that could describe any firm in the sector
  • no use of the firm’s own data on customers, transactions or SARs
  • ratings without explanation of the reasoning behind them
  • controls assumed to be effective without testing
  • no link between the business-wide assessment and the customer risk methodology
  • out-of-date assessments that don’t reflect new products, markets or channels
  • actions identified but not tracked or delivered
  • no evidence of board or senior management review and challenge

What Good Looks Like

A strong business-wide risk assessment is specific, evidence-based and alive. It describes this firm, uses its data, explains its reasoning, links clearly to controls and resources, and changes when the business does. It is short enough for the board to read and engage with, with the detailed analysis in appendices. And it is owned by an MLRO who uses it to run the function, not filed away until the next review.

Firms without the internal capacity to produce one often bring in an interim MLRO or a fractional MLRO with experience in their sector. As the function grows, a deputy MLRO often takes on much of the analytical work.

MLRO and Financial Crime Recruitment

The people who own the risk assessment. Every SMF search is led personally by Adrian Lawrence FCA

Practice Area

MLRO


The owner of the assessment.

→ SMF17 recruitment → Fractional MLRO
What is an MLRO? →
Practice Area

Financial Crime Team


Deputies, heads and specialists.

→ Financial crime leadership → Deputy MLROs
Head of financial crime or MLRO? →
Practice Area

Combined Role


Compliance officer and MLRO.

→ Joint SMF16 and SMF17 → Interim cover
SMF16 and SMF17 explained →
Practice Area

Related Guides


The controls the assessment drives.

→ Transaction monitoring → CDD and EDD
The MLRs explained →

Every SMF search is led personally by Adrian Lawrence FCA

Frequently Asked Questions

Is the business-wide risk assessment a legal requirement?

Yes. Regulation 18 of the Money Laundering Regulations 2017 requires firms in scope to identify and assess their money laundering and terrorist financing risks, record the assessment in writing and keep it up to date.

How often should it be updated?

The Regulations require it to be kept up to date. Most firms review it at least annually and whenever there is a material change in the business or the risk environment.

Can a consultant write it for us?

Consultants can help, but the firm must own the conclusions, and the MLRO should be able to explain and defend them. A document the firm doesn’t understand is a weakness, not a control.

Does the board have to approve it?

The Regulations require senior management approval of the policies, controls and procedures that follow from it. Most firms also present the assessment itself to the board for review and approval.

Does it cover sanctions and fraud?

The legal requirement covers money laundering and terrorist financing, but many firms include sanctions and fraud risk in the same assessment, or in linked assessments, because the controls overlap.

About the Author

Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices. He leads every SMF Capital search personally. View Adrian’s ICAEW profile.

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