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AML Individual CMRA Form B - PC

Process B - Individual

CLIENT INFORMATION

SECTION A | FILE DETAILS

SECTION B - ADDITIONAL INFORMATION

SECTION C | CONFLICT CHECKS

Personal association between member of firm and client?
Email with COLP Approval located on ActionStep

CLIENT AML RISK ASSESSMENT (FEs TO COMPLETE)

1. Individual Client(s) Are we receiving instructions from the client(s) themselves?
(If we are receiving instructions from a representative of the individual, has the representative been verified as properly able to instruct us on behalf of the individual?)
Tick to Confirm evidence is located in ActionStep.
2. Regulated Client(s) Are they a member of a regulated body?
(If so, copy of the Regulator’s register relating to the Individual is sufficient for ID checks.)
3. Unregulated Client(s) Have you obtained appropriate evidence of ID?
Tick to Confirm evidence is located in ActionStep.
4. Have you met the individual(s) providing the instructions (in person or via video call)?
5. Can you confirm that the photo ID of the individual(s) provided is that individual / are those individuals?
6. Have you received all necessary due diligence material to fully understand who your client is?
7. Has there been any adverse media relating to this client? If yes, then have you considered the impact of this on our instruction?
8. Is the client a PEP or Sanctioned? If yes, why do you consider that we can act?

HIGH RISK THIRD COUNTRY

Have you confirmed that the individual(s)’s country of residence / company’s primary business is not a High Risk Third Country?
Have you confirmed that the individual(s) / company are not operating from or in a High Risk Third Country?
NB: HIGH RISK THIRD COUNTY DETAILS CHANGE FROM TIME TO TIME PLEASE ENSURE YOU CHECK FOR EACH NEW CLIENT IF OUTSIDE THE UK –
www.lawsociety.org.uk.url or https://www.legislation.gov.uk/uksi/2021/392/made

IF HIGH RISK THIRD COUNTRY, PLEASE CEASE USING THIS PROCESS AND USE PROCESS C.

MATTER AML RISK ASSESSMENT (FEs TO COMPLETE)

AML RISK FACTORS

GENERAL RISK ASSESSMENT (FEs TO COMPLETE) Please answer all the questions below.

GENERAL RISK FACTORS
If anything in the General Assessment has raised concerns, do you require approval to proceed?
Email with COLP Approval located on ActionStep

ASSESSMENT OF RISK

AML Risk Rating
Operational Risk Rating

Overall risk level guidance note: Low AML Risk unless client or their instructions are unusual or outside of our standard risk assessment for this process. High AML Risk if an individual is PEP or sanctioned or if the client is in a high-risk jurisdiction. There is a Medium General Risk if the answer to any questions in the General Matter Risk Assessment are yes.

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