The following risk factors may be relevant when identifying the risk associated with a customer’s or beneficial owner’s nature and behavior. Firms should note that not all of these risk factors will be apparent at the outset; they may emerge only once a business relationship has been established:

a) Does the customer have legitimate reasons for being unable to provide robust evidence of their identity, perhaps because they are an asylum seeker?

b) Does the firm have any doubts about the veracity or accuracy of the customer’s or beneficial owner’s identity?

c) Are there indications that the customer might seek to avoid the establishment of a business relationship? For example, does the customer look to carry out one transaction or several one-off transactions where the establishment of a business relationship might make more economic sense?

d) Is the customer’s ownership and control structure transparent and does it make sense? If the customer’s ownership and control structure is complex or opaque, is there an obvious commercial or lawful rationale?

e) Does the customer issue bearer shares or does it have nominee shareholders?

f) Is the customer a legal person or arrangement that could be used as an asset-holding vehicle?

g) Is there a sound reason for changes in the customer’s ownership and control structure?