More than ever, evaluating risk and regularly updating your risk assessment is vital to applying the proper resources to prevent money laundering and terrorist financing.
Without an effective, honest assessment, financial institutions, casinos, and money and payment remittance companies face increased exposure and liability due to the misapplication of AML efforts. The Joint Committee of the three European Supervisory Authorities has placed specific emphasis on risk assessments in their newest guidance in response to ever-changing technology, product, customer, geographic and criminal environments.
If your 2017 risk assessment looks exactly like it did in 2015, there are likely gaps that you aren't aware of in your compliance program. Ignorance is rarely a defense for negligence...
Directive (EU) 2015/849 puts the risk-based approach at the centre of the EU's AML/CFT regime. It recognises that the risk of money laundering and terrorist financing may vary and that Member States, competent authorities and credit and financial institutions should identify and assess risks in order to decide how to best manage it.