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AI Summary of 2.10

Version date: 1 March 2021 - onwards

2.10

Firms should note that the nature and purpose of the business relationship, or the type of business, will often determine the relative importance of individual country and geographical risk factors. For example:

a) Where the funds used in the business relationship have been generated abroad, the level of predicate offences to money laundering and the effectiveness of a country’s legal system will be particularly relevant.

b) Where funds are received from, or sent to, jurisdictions where groups committing terrorist offences are known to be operating, firms should consider to what extent this could be expected to or might give rise to suspicion, based on what the firm knows about the purpose and nature of the business relationship.

c) Where the customer is a credit or financial institution, firms should pay particular attention to the adequacy of the country’s AML/CFT regime and the effectiveness of AML/CFT supervision.

d) Where the customer is a trust or any other type of legal arrangement, or has a structure or functions similar to trusts such as, fiducie, fideicomiso, Treuhand, firms should take into account the extent to which the country in which the customer and, where applicable, the beneficial owner are registered effectively complies with international tax transparency and information sharing standards.