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Default Question Set
Updated over a year ago

Customer risk factors

  • Business relationship conducted in unusual circumstances

  • Customer is a legal person or legal arrangement that is a vehicle for holding personal assets

  • Customer is a company that has nominee shareholders or shares in bearer form

  • Customer is a business that is cash-intensive

  • Corporate structure of the customer is unusual or excessively complex given the nature of the company’s business

  • Customer is the beneficiary of a life insurance policy

  • Customer is a third-country national who is applying for residence rights or citizenship of an EEA state in exchange for transfers of capital, purchase of a property, government bonds or investment in corporate entities in that EEA state.

Product, service, transaction or delivery channel risk factors

  • Product involves private banking

  • Product or transaction is one that might favour anonymity

  • The situation involves non-face-to-face business relationships or transactions, without certain safeguards, such as electronic identification processes which meet acceptable safeguards

  • Payments will be received from unknown or unassociated third parties

  • New products and new business practices are involved, including new delivery mechanisms, and the use of new or developing technologies for both new and pre-existing products

  • Service involves the provision of nominee directors, nominee shareholders or shadow directors, or the formation of companies in a third country

  • There is a transaction related to oil, arms, precious metals, tobacco products, cultural artefacts, ivory and other items related to protected species, and other items of archaeological, historical, cultural and religious significance or of a rare scientific value.

Geographical risk factors

  • The customer is a resident in a geographical area of high risk

  • Countries identified by credible sources, such as mutual evaluations, detailed assessment reports or published follow-up reports, as not having effective systems to counter money laundering or terrorist financing

  • Countries identified by credible sources as having significant levels of corruption or other criminal activity, such as terrorism, money laundering, and the production and supply of illicit drugs

  • Countries subject to sanctions, embargos or similar measures issued by, for example, the European Union or the United Nations; 101 anti-money laundering and counter-terrorist financing guidance for the accountancy sector

  • Countries providing funding or support for terrorism

  • Countries that have organisations operating within their territory that have been designated either by the government of the United Kingdom as proscribed organisations under Schedule 2 to the terrorism act 2000(a), or else by other countries, international organisations or the European Union as terrorist organisations

  • Countries identified by credible sources as not implementing requirements to counter money laundering and terrorist financing that are consistent with the recommendations published by the Financial Action Task Force in February 2012 and updated in October 2016.

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