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2.2.1. Product Risk Factors

يسري تنفيذه من تاريخ 31/10/2022

Product risk is assessed by identifying how vulnerable a product is to money laundering and terrorist financing based on the product’s design. Product risk should be assessed periodically and when significant changes are made to product offerings, including the development of new products, services, or technologies. Product risk is a significant factor in identifying unusual activity.

The following table describes attributes used to assess the vulnerability of product offerings and provides lower-and higher-risk examples of each.

AttributeLower-risk exampleHigher-risk example
Ability to hold funds or transact large sumsProduct design that does not hold a balance or cannot be withdrawn against, such as group benefitsProduct design that allows funds to be held on behalf of the customer; high-value or unlimited-value premium payments, overpayments, or large volumes of lower-value payments
Customer anonymity or third-party transactionsProduct design that only allows transactions from customers with identification, or where all funds flow back to the customerProduct design that allows deposits and payments by third parties or that provides for non-face-to-face transactions (e.g., mobile apps where payment source is unknown)
LiquidityProduct design that does not permit withdrawals or includes significant fees or other penalties for early withdrawalsProduct design that has no (or no significant) fees or other penalties for early withdrawal
Time horizonProducts that are typically held for a long period of time, such as years, until retirement or deathProducts that are typically held for a shorter time period
Purpose or intended use of the productProduct design makes it easy to identify if products are not being used as intendedProduct design makes it difficult to identify if products are not being used as intended