4.1.1.1. Customer Risk Rating

Effective from 11/11/2021

LEH should be able to determine whether a particular customer poses higher risk and the potential impact of any mitigating factors on that assessment. Such categorization may be due to the occupation, behavior, or activity of customers. Accordingly, the LEH should assess the risk of key customer elements in order to generate an overall customer rating. Generally, the list of elements includes but is not limited to the following:

	•	Customer’s address and country.
	•	Type of customer (Domestic, foreign, company/corporate, cash-intensive business, etc.).
	•	Industry in which the customer does business.
	•	Anticipated transactional activities.
	•	Customer’s source of wealth.
	•	ML/FT risk of the customer’s industry
	•	The beneficial owners.
	•	Purpose of the relationship or transactional activities.

Below are some examples of risk factors that could be considered by the LEH:

	•	Customers conducting their business or transactions in an unusual manner.
	•	Customers who travel unexplained distances to locations to conduct transactions.
	•	Customers who are Politically Exposed Persons (PEPs) or their direct family members or known close associates and customers whose beneficial owner is a PEP.
	•	Customers involved in transactions that have no apparent ties to the destination country and with no reasonable explanations.
	•	Customers who have been the subject of legal proceedings in relation to proceeds-generating crimes known to the LEH.