[FIRM NAME] Firm-wide Risk Assessment

1y ago
11 Views
1 Downloads
250.13 KB
5 Pages
Last View : 1m ago
Last Download : 1m ago
Upload by : Javier Atchley
Transcription

[FIRM NAME] – Firm-wide risk assessmentUnder the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018), it is a requirement for every accountancy firm to have adocumented firm-wide risk assessment. Before beginning this exercise, you should review the; CCABI’s Anti-Money Laundering Guidance For TheAccountancy Sector CCABI’s Anti-Money Laundering Guidance For The Accountancy Sector (AMLGAS). We’d also recommend reading the National RiskAssessment For Ireland and FATF Guidance for a Risk-Based Approach for the Accounting Profession . Trends and risks within money laundering isconstantly changing. As the MLRO, it’s imperative to keep up to date by reading relevant materials such as those listed to help assess the risk associatedwith your firm. The firm wide risk assessment should be reviewed and updated on an annual basis. Below we have created a template with some hintsand tips to aid our firms in completing an AML Firm-wide risk assessment.Assessment of risk[Every accountancy firm will have risks. Therefore, it’s important toidentify them. In this column detail the risks your firm may have]Mitigating actions[In this column, you should state how you will alleviate the risk posed]Client riskThis section is the most significant. The range of clients and the associated risks are diverse and vast. You must consider whether your clients and itsstakeholders have characteristics associated with money laundering, financial crime and terrorist financing. This list is not exhaustive, but here are justsome examples; Unusual or excessively complex ownership structures & undue secrecy Cash-intensive businesses High-Net Worth Individuals or Politically Exposed Persons (PEP) Association with high-risk jurisdictions Criminal convictions or adverse media High-value businesses (e.g. jewellers, car dealerships) Type of Industry/Business of the firm (e.g. MSBs and import/export services would typically be considered as high-risk)Highlight your client risk in this section. It should look something like this We have two clients operating in high risk jurisdictions.Many of our clients operate cash intensive businesses such asrestaurants, hairdressers and bars.We do not have any high-net worth individuals or PEPs. A client risk assessment is completed on each client during the onboarding stage and annually during our ongoing monitoring process.Every client is given a risk rating of either; low, medium or high.

We have several high-value businesses; high-end propertyrental/sales, wholesalers We have one charity. CDD is performed on all clients deemed to be low or medium risk toverify client identity and business activities. EDD, including sanctionsscreening, is performed on all clients deemed to be high-risk; such asthe ones stated in the assessment of risk column. We review the CDDfiles every year. The firm’s policies and procedures list the additionalchecks required such as independently verifying documentationprovided by the client. Staff are provided with training to identify risks. This is conducted bythe MLRO annually and external bi-annually. Training covers; redflags, case studies, relevant AML regulations, tipping-off, CDD, SARs,how to deal with suspicious transactions. An assessment is conductedto ensure staff understanding. All new clients are approved by the MLRO and one partner.Geography riskYou should consider whether your clients are established or linked to jurisdictions that are regarded as high risk of money laundering or terroristfinancing. You should either compile your own list of high-risk jurisdictions in your AML Policy or make use of high-risk lists provided by reputable sourcesincluding: FATF’s high-risk and other monitored jurisdictions European Commission list of countries with weak anti-money laundering and terrorist financing regimes Sanctions List: Central Bank of Ireland, HM Treasury, OFSI, EU and UN. Transparency International - Corruption Perception IndexBelow is a typical example We have clients who are based locally, nationally and overseas.We have reviewed the FATF, European Commission and Sanction list andalthough we have overseas clients, none operate in high risk countries.Although we have no clients operating in high-risk countries, we have systemsand controls in place to address this risk. This includes

Any client based nationally or overseas would be subject to additional checks –as its rare for our firm to offer services to clients outside of the immediatearea. These checks would include Products and services riskIn this section, you should consider whether any of your products or services have attributes known to be used by money launderers or terroristfinanciers.A national risk assessment identified the following areas of business asposing the highest AML risk within the accountancy sector: Trust and company formation services; to mask the ownership ofassets or transfer assets between persons. False Accounting; to provide a veneer of legitimacy to falsifiedaccounts or documents used to conceal the source of funds. Misuse of client accounts; performing high value financialtransactions for clients with no clear business rationale. Exploitation of Tax services; facilitation of Tax Evasion and VATFraud. Misuse of Insolvency Services.Although the list is not exhaustive, you should consider whether you offer theservices outlined and address how you will manage each risk. For example,staff training to identify red flags, EDD etc.You should consider putting into context the scale of risk. For example, if lessthan 1% of your revenue is generated through Trust and company formationservices then it would be reasonable to consider this to be low risk for yourfirm.Transactions riskAs mentioned, misuse of client accounts is currently considered to be a risk within the accountancy sector. If you hold a client account, put into contextthe risk. You should also consider the risk associated with your office account. Below is a typical example Firm holds one client account. It is only used to receive tax refunds fromRevenue. Usually less than five transactions per year. The amounts arealways less than 10k and in line with what we’d expect for the clientsinvolved.We only provide these services to two long standing clients. Funds are alwaysfrom a known and reputable source. Client account is operated by the MLROand one partner only.

Delivery channels riskDo you meet your clients face to face? If not, you may face greater money laundering or terrorist financing risks because it can be more difficult todetermine the identity and credibility of a client, both at the start of a relationship and throughout its course. You should also consider how and why theclient has come to you. Below is an example All our local and national clients are met face to face at onboarding.We do offer online services – but all clients are met face to face at onboardingand typically at least once a year.We do offer remote services to one overseas client.Although we did not meet the client when onboarding, he was referred to mevia a long-standing customer. I conducted a video call with him and conductedEDD. I have since met the client as well.Overall assessment of riskYou should summarise all the above; highlighting the key areas of risk. You should consider listing any other risks you identified that have not alreadybeen mentioned. It’s also beneficial to provide an overall profile of the firm. Below is an example Overall 10% of our client base are considered higher than normal risk, 80% medium/normal risk and 10% low risk. Those considered low risk, in accordancewith the CCABI guidance, are public owner enterprise or operate in an already regulated market.The majority of our clients work in the xxxx sector – so we are familiar with the type of activity and services they would typically offer.Our clients tend to be local and long-standing.We believe the biggest risk to the firm is XXXX. However, we believe we are mitigating this risk by enforcing the following controls. They are XXXX

ActionsFinally, list what actions you will take to address the risk identified. Below is an example ActionPerform annual compliance review (MLROreport)Conduct AML TrainingReview AML P&PsFirm Wide Risk Assessment conducted by: [MLRO NAME]Shared with: X [Partner of firm] and Y [Director of firm]Completed on:Next review date:Delivery date01/01/2020Owner[STAFF NAME]01/03/202001/06/2020[STAFF NAME][STAFF NAME]

The firm wide risk assessment should be reviewed and updated on an annual basis. Below we have created a template with some hints and tips to aid our firms in completing an AML Firm-wide risk assessment. Assessment of risk [Every accountancy firm will have risks. Therefore, it’s important to

Related Documents:

At Your Name Name above All Names Your Name Namesake Blessed Be the Name I Will Change Your Name Hymns Something about That Name His Name Is Wonderful Precious Name He Knows My Name I Have Called You by Name Blessed Be the Name Glorify Thy Name All Hail the Power of Jesus’ Name Jesus Is the Sweetest Name I Know Take the Name of Jesus

Risk Matrix 15 Risk Assessment Feature 32 Customize the Risk Matrix 34 Chapter 5: Reference 43 General Reference 44 Family Field Descriptions 60 ii Risk Matrix. Chapter 1: Overview1. Overview of the Risk Matrix Module2. Chapter 2: Risk and Risk Assessment3. About Risk and Risk Assessment4. Specify Risk Values to Determine an Overall Risk Rank5

Risk is the effect of uncertainty on objectives (e.g. the objectives of an event). Risk management Risk management is the process of identifying hazards and controlling risks. The risk management process involves four main steps: 1. risk assessment; 2. risk control and risk rating; 3. risk transfer; and 4. risk review. Risk assessment

81. Risk Identification, page 29 82. Risk Indicator*, page 30 83. Risk Management Ω, pages 30 84. Risk Management Alternatives Development, page 30 85. Risk Management Cycle, page 30 86. Risk Management Methodology Ω, page 30 87. Risk Management Plan, page 30 88. Risk Management Strategy, pages 31 89. Risk

1.5 Tactical Risk Decisions and Crisis Management 16 1.5.1 Risk preparation 17 1.5.2 Risk discovery 17 1.5.3 Risk recovery 18 1.6 Strategic Risk Mitigation 19 1.6.1 The value-maximizing level of risk mitigation (risk-neutral) 19 1.6.2 Strategic risk-return trade-o s for risk-averse managers 20 1.6.3 P

Depositary Receipts (ADRs, EDRs and GDRs) Derivatives XX X Hedging XX X Speculation XX X Risk Factors in Derivatives XX X Correlation Risk X X X Counterparty Risk X X X Credit Risk XX X Currency Risk Illiquidity Risk X X X Leverage Risk X X X Market Risk X X X Valuation Risk X X X Volatility Risk X X X Futures XX X Swap Agreements XX X

Risk analysis Process to comprehend the nature of risk and to determine the level of risk Risk appetite Amount and type of risk that the organization is prepared to take in order to achieve its objectives. Risk assessment Overall process of risk identification , risk analysis and risk eva

The potential benefits of digital risk initiatives include efficiency and productivity gains, enhanced risk effectiveness, and revenue gains. The benefits of Exhibit 1 Digital risk management can significantly reduce losses and fines in core risk areas. Risk 2017 Digital Risk Exhibit 1 of 3 Credit risk Risk areas osses 2015, billion

3 Project Risk Management Process Project risk management involves seven major phases: 1. Risk management planning. 2. Identify risk. 3. Perform risk analysis . 4. Evaluate and prioritize risk. 5. Plan risk response. 6. Implement risk respo nse. 7. Risk monitoring and control.

1.6 how to use this statement 6 2. overall risk appetite statement 6 3. programmatic risk 8 4. fiduciary risk 10 5. reputational risk 12 6. legal risk 14 7. security risk 16 8. human-capital risk 19 9. information-technology risk 21

Tunnelling Risk Assessment 0. Abstract 1. Introduction and scope 2. Use of risk management 3. Objectives of risk assessment 4. Risk management in early design stages 5. Risk management during tendering and contract negotiation 6. Risk management during construction 7. Typical components of risk management 8. Risk management tools 9. References .

Standard Bank Group risk management report for the six months ended June 2010 1 Risk management report for the six months ended 30 June 2010 1. Overview 2 2. Risk management framework 3 3. Risk categories 6 4. Reporting frameworks 8 5. Capital management 10 6. Credit risk 17 7. Country risk 36 8. Liquidity risk 38 9. Market risk 42 10 .

Correlation with market risk Non-diversifiable credit risk including contagion Downgrade risk ¾Market spreads can't be ignored Reinsurance spread might be higher Default/recovery could be higher or lower Liquidity low Downgrade risk higher Credit Risk Correlations Insurance risk Insurance business Equity risk, other investment risk

LAW FIRM NAMES - AMENDMENTS TO RPC 7.5 AND COURT RULES 1:21-1A, 1:21-1B, AND 1:21-1C The Supreme Court has adopted amendments to Rule of Professional Conduct 7.5 ("Law Firm Names and Letterheads") so as to remove the requirement that the law firm name include the name of a lawyer and describe the nature of the firm's legal practice.

X6 Feature 8.8 x 3.5 88mm high x 129mm wide X7 Feature 8.8 x 7 88mm high x 262mm wide X8 Feature 17.8 x 3.5 178mm high x 129mm wide X9 Feature 17.8 x 7 178mm high x 262mm wide X10 Feature 7.4 x 3 74mm high x 109mm wide X11 Feature 7.4 x 6 74mm high x 224mm wide BF Banner x 1 380mm high x 33mm wide Front Page

flock to the piece rate firm. After the price of output falls, firm A values all workers at 17.50 per hour, while worker 1’s value at firm B falls to 50 cents, worker 2’s value falls to 1 at firm B, etc. The question is what happens to the wage. Presumably wage also falls, to 17.50 per hour in firm A.

associates or otherwise employed in the firm "not to (1) actively exploit their positions within the [law firm] for their own personal benefits, or (2) hinder the ability of the [law firm] to conduct the business for which it was developed." Burke v. Lakin Law Firm, 2008 WL 64521 (S.D.Ill. Jan. 3, 2008), quoting FoodComm Intern. V.

FIRM Database Technical Reference Guidelines and Standards for Flood Risk Analysis and Mapping Page 2 FIRM Database Technical Reference 1. FIRM Database Overview The FEMA FIRM Database will store the digital GIS data used in the map production process, as well as tabular information inside the Flood Insurance Study (FIS) r eport. The

Risk Management: the Process Risk Management is a broad standard (ISO 31000) Risk Identification Risk Evaluation Development and evaluation of risk assessment methods Risk management decisions Implemented solution Identify all relevant risks (e.g., hazard analysis) Quantify the risk (e.g., probability and severity) Implement a process

Click 500 series – Customizable devices built on our Click 500 platform This user guide covers the Click 500 series. For the Click 100–400 series, please see the Click 100–400 Series User Guide. Using this Manual This manual is divided into two parts: Part I: Introduction to the Click Series – This part contains information common to the Click line, beginning with basic module .