AML/CFT Risk Assessment – Risk Analysis and Recommendations
An AML/CFT risk assessment identifies where and to what extent your organisation may be exposed to money laundering and terrorist financing risk. At Dueveris AML, we identify risks related to customers, products, transactions, service channels and geographic exposure, assess the effectiveness of existing controls, and prepare practical recommendations for management and the compliance team.
SPEAK WITH AN EXPERT ABOUT AML/CFT RISK ASSESSMENTDoes Your Risk Assessment Still Reflect How Your Business Operates?
An AML/CFT risk assessment should show where your organisation is currently most exposed to risk and whether existing controls are sufficient. If it describes the business as it operated before key changes, it does not provide a reliable basis for decision-making.
It is worth reviewing when:
The Assessment Was Prepared Several Years Ago
The document has not been updated despite changes within the organisation and its business environment.
The Company Has Launched a New Product or Service
A new delivery model may change the AML/CFT risk profile.
Sales or Service Channels Have Changed
Remote onboarding, intermediaries, platforms or new digital channels require reassessment.
Customer, Transaction or Geographic Volumes Are Increasing
The scale and reach of the business increase risk exposure.
Outsourcing or New Tools Have Been Introduced
Changes to the operating model affect controls, oversight and escalation processes.
The Document Does Not Identify the Key Risks
The assessment describes many areas but does not show which require urgent action.
The AML Procedure Does Not Reflect the Company’s Actual Risk
Operating rules are too general or do not reflect the organisation’s customers, products and processes.
Management Does Not Have a Clear View of Residual Risk
It is unclear what risk remains after existing AML/CFT controls have been applied.
Organisation-Wide Risk Assessment Is Not the Same as Customer Risk Assessment
These are two different levels of analysis. An organisation-wide risk assessment shows where the business is exposed to AML/CFT risk across its operating model. A customer risk assessment supports decisions about a specific relationship.
| Organisation-Wide Risk Assessment | Customer Risk Assessment |
|---|---|
| Analyses the company’s business model | Analyses a specific individual or business |
| Covers customers, products, geographies, transactions and service channels | Applies to a specific business relationship or transaction |
| Identifies where stronger AML/CFT controls are needed | Determines the scope of KYC, EDD and monitoring |
| Provides the basis for procedures, governance and action plans | Forms part of onboarding and ongoing monitoring |
An organisation-wide risk assessment answers: Where is the company exposed? A customer risk assessment answers: What risk is associated with this specific relationship?
What Does Dueveris AML Analyse as Part of an AML/CFT Risk Assessment?
We assess not only the level of risk, but also what drives it and whether existing controls genuinely reduce it.
Customers and Customer Segments
We analyse customer profiles, industries, ownership structures, foreign customers, PEPs and other factors that increase risk exposure.
Products, Services and Transactions
We assess which products, settlement models and transaction types may create elevated AML/CFT risk.
Countries and Geographic Exposure
We review countries of operation, customer origins, transaction flows and relationships with higher-risk jurisdictions.
Service and Distribution Channels
We assess risks linked to remote onboarding, intermediaries, partners, platforms, APIs and digital channels.
AML/CFT Processes and Controls
We assess whether KYC, KYB, screening, monitoring, reporting and escalation processes are appropriate for the identified risks.
Oversight and Responsibilities
We analyse role allocation, management reporting, data quality, internal controls and the way AML/CFT decisions are made.
From Risk Assessment to Practical AML Changes
A risk assessment should lead to specific decisions on AML/CFT processes, controls and priorities.
| Area | Inherent Risk | Controls in Place | Residual Risk |
|---|---|---|---|
| Foreign customers | Elevated | KYC, screening, monitoring | Moderate |
| Remote onboarding | Elevated | Identity verification, quality assurance | Moderate |
| Complex corporate structures | High | KYB, beneficial ownership analysis, EDD | Elevated |
If a control exists only in a procedure or is not applied consistently, risk remains high despite formally implemented safeguards.
How Does Dueveris AML Conduct an AML/CFT Risk Assessment?
The assessment is based on data, real processes and the way your organisation operates – not solely on written procedures.
1. Understanding the Business Model
We analyse customers, products, transactions, countries, service channels, systems and the operating structure.
2. Collecting Data and Documentation
We review procedures, customer data, volumes, alerts, reports, audit findings and existing AML/CFT controls.
3. Identifying Sources of Risk
We identify the areas in which the organisation may be most exposed to AML/CFT risk.
4. Assessing Existing Controls
We assess whether KYC, KYB, screening, monitoring, escalations and oversight are appropriate for the identified risks.
5. Identifying Risks Requiring Action
We determine which risks are acceptable and which require additional controls, process changes or management decisions.
6. Preparing Recommendations and an Action Plan
We provide priorities, recommended changes and a clear action plan for management and the team.
What Does a Well-Conducted AML/CFT Risk Assessment Change?
It gives the organisation a clear view of where AML/CFT risk is highest, which controls are effective and which require strengthening.
The result is not only a risk-assessment document, but also clear priorities for management and the team: which processes to change, which safeguards to implement, and where additional action, training or oversight is needed.
From Risk Assessment to Practical AML Changes
A risk assessment should lead to specific decisions on AML/CFT processes, controls and priorities.
| Risk Assessment Finding | Example Action |
|---|---|
| Elevated risk related to corporate customers | Strengthen KYB and beneficial ownership analysis |
| Risk in remote onboarding | Improve identity verification and quality assurance |
| Elevated transaction risk | Update monitoring scenarios and alert-handling rules |
| Inconsistent KYC decisions | Clarify risk criteria and calibrate the team |
| Unclear escalation rules | Update the AML/CFT procedure and allocation of responsibilities |
| High risk despite existing controls | Prepare a remediation plan, conduct an audit or engage an External AML Officer |
AML/CFT Risk Assessment, Procedure or Audit?
These services address different needs, but can work together as part of one AML/CFT framework.
| Organisational Need | Appropriate Service |
|---|---|
| Understand where the business is exposed to AML/CFT risk | AML/CFT Risk Assessment |
| Define operating rules, roles and escalation paths | AML/CFT Procedure |
| Assess whether the process works effectively in practice | AML/CFT Audit |
| Implement changes and provide ongoing AML/CFT oversight | External AML Officer |
| Deliver day-to-day operational activities | AML Outsourcing |
A risk assessment shows where the organisation is exposed. A procedure defines how to act. An audit checks whether the rules are applied in practice.
Engagement Models
We tailor the scope of work depending on whether your organisation is building a risk assessment from scratch, updating an existing document or preparing for a specific change.
Full AML/CFT Risk Assessment
For organisations that need a comprehensive review of their business activities, risks, controls and action priorities.
Update of an Existing Risk Assessment
For businesses that have an existing document, but it no longer reflects their current products, customers, processes or scale of operations.
Risk Assessment Before a Business Change
For a new product, market, sales channel, partner, system or customer-service model.
Risk Assessment Following an Audit or Inspection
For organisations that want to structure recommendations, define priorities and prepare a remediation plan.
Want to understand where your organisation is genuinely exposed to AML/CFT risk?
Let’s discuss a risk assessment tailored to your business model, customers, products and processes.
Email Us
office@dueverisaml.pl
