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AML Entity CMRA Form A - PC

Process A – Entity

CLIENT INFORMATION

SECTION A | FILE DETAILS

SECTION B | CONFLICT CHECKS

Personal association between member of firm and client?
Email with COLP Approval located on ActionStep

CLIENT AML RISK ASSESSMENT (FEs TO COMPLETE)

1. Instructing Individual Are we receiving instructions from an appropriately senior individual within the entity with authority to instruct us? (If we are receiving instructions from someone other than an employee of the company, you must obtain written authorisation from the company instructing us.)
Tick to Confirm evidence is located in ActionStep.
2. If a third party is instructing, do we have evidence of their authority to act and have we undertaken appropriate ID checks?
Tick to Confirm evidence is located in ActionStep.
3. Have you verified the client’s identity from an independent and reputable source?
(for example: companies house, charities commission or professional body)
Tick to Confirm evidence is located in ActionStep.
4. If your client is not verifiable against an independent and reputable source, have you obtained Veriphy checks for two of the Directors/Owners?
Tick to Confirm evidence is located in ActionStep.
5. Have you met the individual(s) providing the instructions (in person or via video call)?
6. Can you confirm that the photo ID of the individual(s) provided is that individual / are those individuals?
7. Have you received all necessary due diligence material to fully understand who your client is?

HIGH RISK THIRD COUNTRY

Have you confirmed that the individual(s)’s country of residence / company’s primary business is not a High Risk Third Country?
Have you confirmed that the individual(s) / company are not operating from or in a High Risk Third Country?

NB: HIGH RISK THIRD COUNTY DETAILS CHANGE FROM TIME TO TIME PLEASE ENSURE YOU CHECK FOR EACH NEW CLIENT IF OUTSIDE THE UK –
www.lawsociety.org.uk.url or https://www.legislation.gov.uk/uksi/2021/392/made

IF HIGH RISK THIRD COUNTRY, PLEASE CEASE USING THIS PROCESS AND USE PROCESS C.

MATTER AML RISK ASSESSMENT (FEs TO COMPLETE)

AML RISK FACTORS

GENERAL RISK ASSESSMENT (FEs TO COMPLETE) Please answer all the questions below.

GENERAL RISK FACTORS
If anything in the General Assessment has raised concerns, do you require approval to proceed?
Email with COLP Approval located on ActionStep

ASSESSMENT OF RISK

AML Risk Rating
Please seek guidance from COLP is any other rating than low
Operational Risk Rating
Please seek approval before continuing

Overall risk level guidance note: Low AML Risk unless client or their instructions are unusual or outside of our standard risk assessment for this process. High AML Risk if you are unable to verify the client’s identity against a reputable source or if the client is in a high-risk jurisdiction. There is a Medium General Risk if the answer to any questions in the General Matter Risk Assessment are yes.

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