• All or none of the customers are rated high risk.
• Compliance department or auditors can’t explain
risk rating categories or the linkage between risk
ratings and other components of the AML / ATF
Program.
• Customers that are subjects of investigations / STRs
are rated low risk.
• High risk customers are assessed as low risk
because they are involved with low risk business
lines (and the reverse also applies).
¾ e.g. clients offering funds transfer services,
dealers in high value goods, etc