You may use the following matrix, as appropriate, when assessing the level of money laundering and terrorist financing risks of your products, services and clients. The following matrix is inspired from a matrix included in a recent document on risk-based approach published by the Financial Action Task Force (FATF).
| Low | Moderate | High |
|---|---|---|
| Stable, known client base | Client base increasing due to branching, merger, or acquisition | A large and growing client base in diverse geographic area |
| No electronic transaction services or the Web site is informational or non-transactional | You are beginning electronic transaction services and offer limited products and services. | You offer a wide array of electronic transaction services (i.e., account transfers, or acccounts opened via the Internet). |
| There are few or no large currency transactions. | There is a moderate volume of large currency or structured transactions. | There is a significant volume of large currency or structured transactions. |
| Identified a few high-risk clients and businesses | Identified a moderate number of high-risk clients and businesses | Identified a large number of high-risk clients and businesses |
| Few international accounts or very low volume of currency activity in the accounts | Moderate level of international accounts with unexplained currency activity | Large number of international accounts with unexplained currency activity |
| A limited number of fund transfers for clients, non clients, limited third-party transactions, and no foreign funds transfers | A moderate number of fund transfers, a few international fund transfers from personal or business accounts with typically low-risk countries | Frequent funds from personal or business accounts to or from high-risk jurisdictions, and financial secrecy havens or jurisdictions. |
| Your business is located in an area known to have low crime rate. | Your business is located in an area known to have moderate crime rate. | Your business is located in an area known to have high crime rate. |
| No transactions with high-risk geographic locations | Minimal transactions with high-risk geographic locations | Significant volume of transactions with high-risk geographic locations |
| Low turnover of key anti-money laundering personnel and frontline personnel (i.e., client service representatives, tellers, or other personnel) | Low turnover of key anti-money laundering personnel, but frontline personnel may have changed | High turnover, especially in key anti-money laundering personnel positions |