Thursday, December 8, 2011

Risk Rating questions for a corporate customer

Collecting CDD/EDD information on corporate customers can help with customer AML risk-rating, if you get to the interesting questions, and apply risk information you already have:

Some sample questions:
  1. Nature of business/industry (implies a listing or set of high-risk business types)
  2. Type of business formation
  3. Jurisdiction of business formation (apply country risk factor)
  4. Business privately held or publicly traded?
    1. If publicly traded are shares on a recognized exchange (implies listing of acceptable exchanges worldwide.)
  5. Identification of beneficial owners:
    1. Document direct owners
    2. Document indirect owners
    3. Calculate actual ownership
    4. Drive to statutory required level (say 10%)
    5. Drive to actual persons as beneficial owners
  6. Identification of board members, senior management, other signatories
  7. Types of products to be used (implies a risk assessment of products, for example)
    1. Lower Risk (savings account, certificates of deposit, basic demand deposit)
    2. Moderate Risk (lending, financing, certain kinds of investment products)
    3. Higher Risk (cash services, wires, ACH, standby letters of credit, etc.)
  8. Listing of expected counter-party countries (from list, and applying country risk factors)
  9. Expected value, volume, variations
  10. Screen of signatories, beneficial owners, board members, senior managers;
    1. Cases (this is a little controversial)
    2. Sanctions
    3. Negative news

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