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AML Risk Assessment Form

AML Risk Assessment Form Template for Pakistan

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Key Requirements PROMPT example:

AML Risk Assessment Form

"I need an AML Risk Assessment Form for a Pakistan-based fintech company that's planning to launch digital payment services across APAC region in March 2025, with particular focus on cross-border transactions and digital channel risks."

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Document background
The AML Risk Assessment Form is a mandatory compliance document required for organizations operating within Pakistan's financial and designated non-financial sectors. This document is essential for meeting the requirements established under Pakistan's Anti-Money Laundering Act 2010 and subsequent regulations. Organizations must complete this assessment periodically to identify, assess, and document their exposure to money laundering and terrorist financing risks. The form encompasses evaluation of customer profiles, geographic exposure, products and services, delivery channels, and transaction patterns. It serves as both a regulatory compliance tool and a strategic risk management instrument, helping organizations develop appropriate control measures and allocate resources effectively. The assessment must be updated regularly and whenever significant changes occur in the business or regulatory environment.
Suggested Sections

1. Institution Information: Basic details of the reporting entity including name, license type, business nature, and regulatory status

2. Risk Assessment Methodology: Description of the approach used for risk assessment, including scoring methods and risk calculation formulas

3. Customer Risk Assessment: Evaluation of risks associated with different customer types, profiles, and behaviors

4. Geographic Risk Assessment: Analysis of risks related to different jurisdictions, high-risk countries, and sanctions lists

5. Product/Service Risk Assessment: Evaluation of risks associated with different products and services offered

6. Delivery Channel Risk Assessment: Assessment of risks related to different methods of service delivery and transaction channels

7. Transaction Risk Assessment: Analysis of transaction patterns, volumes, and associated risks

8. Overall Risk Rating: Final risk classification and justification based on combined risk factors

9. Control Measures: Existing AML controls and their effectiveness in mitigating identified risks

10. Action Items: Recommended actions to address identified risks and enhance controls

Optional Sections

1. Correspondent Banking Risk Assessment: Additional section for banks maintaining correspondent banking relationships

2. Digital Payment Services Risk Assessment: For institutions offering digital payment or fintech services

3. Cross-Border Operations Assessment: For institutions with international operations or cross-border transactions

4. High-Risk Customer Segment Analysis: Detailed assessment of specific high-risk customer segments

5. Sanctions Compliance Assessment: Detailed evaluation of sanctions screening and compliance programs

6. Employee Risk Assessment: Evaluation of staff-related ML/TF risks and insider threats

Suggested Schedules

1. Risk Scoring Matrix: Detailed methodology and criteria for risk scoring across different categories

2. Customer Risk Factors: Comprehensive list of customer risk factors and their weightings

3. Geographic Risk Factors: List of high-risk jurisdictions and their risk classifications

4. Red Flag Indicators: List of suspicious activity indicators and red flags

5. Control Assessment Checklist: Detailed checklist for evaluating AML/CFT controls

6. Risk Assessment Review Schedule: Timeline and procedure for periodic review of risk assessments

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Money Laundering
Terrorist Financing
Beneficial Owner
Customer Due Diligence (CDD)
Enhanced Due Diligence (EDD)
Risk Rating
High-Risk Customer
Politically Exposed Person (PEP)
Suspicious Transaction
Currency Transaction Report (CTR)
Suspicious Transaction Report (STR)
Risk Appetite
Risk Tolerance
Control Measures
Inherent Risk
Residual Risk
Financial Action Task Force (FATF)
Sanctions
Risk Factors
Risk Assessment Methodology
Customer Risk Profile
Geographic Risk
Product Risk
Channel Risk
Transaction Risk
Red Flags
Ultimate Beneficial Owner (UBO)
Financial Monitoring Unit (FMU)
Designated Non-Financial Businesses and Professions (DNFBPs)
Know Your Customer (KYC)
Risk Mitigation
Compliance Program
Shell Company
Front Company
Correspondent Banking
High-Risk Jurisdiction
Sanctions Screening
Transaction Monitoring
Alert Threshold
Risk Matrix
Clauses
Purpose and Scope
Confidentiality
Document Control
Methodology
Customer Risk Assessment
Geographic Risk Assessment
Product Risk Assessment
Channel Risk Assessment
Transaction Risk Assessment
Risk Rating Criteria
Control Assessment
Regulatory Reporting
Documentation Requirements
Review and Update
Risk Mitigation
Compliance Attestation
Data Protection
Information Security
Record Keeping
Senior Management Oversight
Staff Training
Internal Controls
External Reporting
Risk Monitoring
Escalation Procedures
Relevant Industries

Banking

Insurance

Securities and Brokerage

Microfinance

Money Service Businesses

Real Estate

Precious Metals and Stones Dealers

Non-Banking Financial Companies

Investment Companies

Credit Unions

Fintech

Cryptocurrency Exchanges

Relevant Teams

Compliance

Risk Management

Internal Audit

Legal

Operations

Customer Due Diligence

Transaction Monitoring

Senior Management

Board of Directors

Financial Crime Prevention

Know Your Customer (KYC)

Regulatory Reporting

Relevant Roles

Chief Compliance Officer

AML Compliance Manager

Risk Assessment Officer

Money Laundering Reporting Officer (MLRO)

Compliance Analyst

Risk Manager

Internal Auditor

Chief Risk Officer

Regulatory Compliance Director

Financial Crime Prevention Officer

KYC Manager

Due Diligence Specialist

Chief Executive Officer

Board Member

Industries
Anti-Money Laundering Act, 2010: The primary legislation in Pakistan that criminalizes money laundering and provides the legal framework for preventing, detecting, and deterring money laundering and terrorist financing
Anti-Money Laundering and CFT Regulations, 2020: Detailed regulations that specify the requirements for conducting risk assessments, customer due diligence, and reporting suspicious transactions
SECP AML/CFT Guidelines, 2020: Securities and Exchange Commission of Pakistan's specific guidelines for financial institutions and DNFBPs on implementing AML/CFT measures and conducting risk assessments
State Bank of Pakistan AML/CFT Regulations: Central bank regulations providing specific requirements for banking sector risk assessments and compliance procedures
FATF Recommendations: International standards that Pakistan follows as part of its commitment to combat money laundering and terrorist financing, particularly relevant for risk assessment methodology
National Risk Assessment Guidelines: Pakistan's national framework for assessing and managing money laundering and terrorist financing risks at both national and institutional levels
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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