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4. Identification and Assessment of ML/FT Risks

Effective from 13/7/2023

(AML-CFT Law Article 16.1; AML-CFT Decision Article 4.1)

Both the AML-CFT Law and the AML-CFT Decision provide that FIs may utilize a risk-based approach with respect to the identification and assessment of ML/FT risks.

FIs are obliged to assess and to understand the ML/FT risks to which they are exposed, and how they may be affected by those risks. Specifically, the AML-CFT Law provides that they shall:

 “…continuously assess, document, and update such assessment based on the various risk factors established in the Implementing Regulation of this Decree-Law and maintain a risk identification and assessment analysis with its supporting data to be provided to the Supervisory Authority upon request.”
 

Furthermore, the AML-CFT Decision charges supervised institutions with:

 “…Documenting risk assessment operations, keeping them up to date on on-going bases and making them available upon request.”
 

Guidance on these subjects is provided in the following sections.