Larger reporting entities should develop a
stronger assessment tool than just a
checklist.
Customers could be clustered by different
risk variables (e.g. products used,
geographic locations, transaction type,
business activity, duration of the
relationship, etc.)
Clusters could then be given a weighting
commensurate with the risk of potential
money laundering/terrorist financing, and
the appropriate mitigating controls that
would be applied.