Risk
What raises risk
The reasons a person can be rated medium or high risk. Each links to the business types that use it, where the rules behind it, and what is asked for because of it, are written out.
Customer factors
Who the customer is, what they do, and how they behave.
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High Medium
Cash-intensive business
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High
Client with significant unexplained wealth
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High
Complex or opaque beneficial ownership structure
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High
Credible adverse media
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High
Customer refuses or delays providing CDD information
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High Medium
Customer's answers contradict each other
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High
Foreign politically exposed person (PEP)
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High
Individuals suspected of profit-generating offences
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High Medium
Legal structures creating effective anonymity
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High
Linked to another case of concern
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High
Multiple moderate risk factors present
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High
Other reasons
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High
Owned or controlled by a sanctioned person or entity
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High
Possible sanctions match not ruled out
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High
Suspected criminal or unusual activity
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High
Suspected false or fraudulent identity
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High
Suspicious matter reported
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High
Wealth sourced through a complex structure
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Medium
Charity or non-profit organisation involvement
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Medium
Customer is a minor
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Medium
Domestic or international-organisation PEP
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Medium
Domestic politically exposed person (PEP)
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Medium
International-organisation politically exposed person (PEP)
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Medium
Non-profit organisation involvement
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Medium
Overseas resident customer
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Medium
Politically exposed person declared: category to be confirmed
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Medium
Third-party representative (individual)
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Medium
Third-party representative is not an evidenced enrolled reporting entity
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Medium
Trust or other legal arrangement
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Medium
Wealth sourced from overseas
Transaction factors
How the deal is paid for and structured.
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High
Contract price inconsistent with the agency's own appraisal
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High
Funded by a private person, syndicate or overseas lender
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High
Funded by a solicitor's loan or contributory mortgage
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High
Funding sourced from a non-institutional or private lending arrangement
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High
Funds from a third party, an undeclared account, or several payers
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High
High value physical currency transaction
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High
High value physical currency transactions
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High
High-risk precious metals or stones
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High
High-value physical currency payment
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High
Money paid in and refunded in a way that launders it
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High
Payment from a third party unrelated to the transaction
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High
Payment using virtual assets
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High
Payments structured to stay under the reporting threshold
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High
Property value implausible for declared income/occupation
-
High
Rapid on-sale or resale shortly after purchase
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High
Sale proceeds directed to an unconnected third party
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High
Scrap metal dealer counterparty
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High Medium
Source of funds inconsistent with customer profile
-
High
Stolen, conflict or counterfeit metals, stones or products
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High
Unusual service request
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High
Unusual virtual asset transaction
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High
Unusually complex, large or purposeless transaction
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Medium
Funded by a non-bank lender or private credit fund
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Medium
Funds from immediate family (a gift or family loan)
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Medium
Funds or wealth from a country with capital controls
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Medium
High-value real estate purchased without a mortgage
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Medium
High-value transaction without third-party finance
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Transactions structured to avoid the reporting threshold
Delivery channel factors
How the service is delivered: in person, remotely, through someone else.
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High Medium
Fully remote, no face-to-face interaction
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High
Suspected false or fraudulent identity via remote channel
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High
Verified remotely from another country or a hidden connection
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Medium
Dealt with through an intermediary or agent
Country factors
Where the people and the money are.
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High
Party resident in a FATF-listed high-risk jurisdiction