Assessing Customer Risk

Client and Business Relationships

The following checklist is intended to provide an example of how to assess risk for your client relationships. This is only a starting point and you should customize the checklist for your business. Your risk assessment tool has to be appropriate for your specific business needs which means that it may have to be more detailed than this checklist for larger reporting entities, or entities who conduct large volumes of business. If you already use another risk assessment tool, you can continue to use it or enhance it as necessary.

If you answer yes to any of the questions below, you should consider it as higher risk for money laundering or terrorist financing. Where appropriate, risk mitigation steps should be taken.

You can also refer to the Financial Action Task Force’s Web site ( for further guidance on risk based approach.

Identify whether any of the following apply to the client: Yes No N/A
For all sectors
Is the client a cash-intensive business?
Does the client’s business generate large amounts of cash for certain transactions that are not normally cash-intensive?
Is the client an intermediary or “gatekeeper” such as a professional that holds accounts for clients where the identity of the underlying client is not disclosed to you?
Does the client use unsupervised intermediaries within the relationship who are not subject to adequate anti-money laundering or anti-terrorist financing obligations?
Does client identification take place other than face-to-face?
Does the client reside outside Belize?
Does the client deal offshore?
Is the client an unregistered charity or other unregulated “not for profit” organization (especially one operating on a “cross-border” basis)?
Is the client located in a known high crime rate area?
Has the client been identified to have engaged in activity that is consistent with the indicators for Suspicious Transactions?
Does the comparison between your clients with similar profiles and high levels of assets or large transactions seem unreasonable?
Does the knowledge of local laws, regulations and rules seem excessive for your client?
Is the client a new client?
Do your clients use intermediate vehicles (such as corporations, trusts, foundations, partnerships) or other structures that do not seem usual for their business or seem very complex and unnecessary?
Does the client offer on-line gaming?
Does the client’s structure or nature of its business or relationship make it difficult to identify the true owners or controllers?
Is there a significant and unexplained geographic distance between you and the location of the client?
Is there frequent and unexplained movement of accounts or funds between institutions in various geographic locations or to different institutions?
Is the client a politically exposed foreign person?
A politically exposed foreign person is an individual who holds or has ever held one of the following offices or positions in or on behalf of a foreign country:

  • a head of state or government;
  • a member of the executive council of government or member of a legislature;
  • a deputy minister (or equivalent);
  • an ambassador or an ambassador’s attaché or counselor;
  • a military general (or higher rank);
  • a president of a state owned company or bank;
  • a head of a government agency;
  • a judge; or
  • a leader or president of a political party in a legislature.

A politically exposed foreign person also includes the following family members of the individual described above:

  • mother or father;
  • child;
  • spouse or common law-partner;
  • spouse’s or common-law partner’s mother or father and
  • brother, sister, half-brother or half-sister (that is, any other child of the individual’s mother or father).
For financial entities
Is the client a foreign financial institution with which you have a correspondent banking relationship?
Is the client a correspondent bank that has been subject to sanctions?