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12.7
The staff member managing a wealth management firm’s relationship with a customer (the relationship manager) typically plays a key role in assessing risk. The relationship manager’s close contact with the customer will facilitate the collection of information that allows a fuller picture of the purpose and nature of the customer’s business to be formed (e.g. an understanding of the client’s source of wealth, the destination of funds, why complex or unusual arrangements may nonetheless be genuine and legitimate, or why extra security may be appropriate). This close contact may, however, also lead to conflicts of interest if the relationship manager becomes too close to the customer, to the detriment of the firm’s efforts to manage the risk of financial crime. Consequently, independent oversight of risk assessment will also be appropriate, provided by, for example, the compliance department and senior management.