The most common result across all sectors relates to the appreciation of risk, both at institutional level and at the customer level. Another common finding relates to the requirements of having a customer risk profile which monitors transactions and to consider occasional ones within the context of all that is known about the customer.
It was noted that Subject Persons were considering particular clients as low risk on the basis of their familiarity with such clients, allowing themselves to be overly influenced rather than basing their risk understanding on a sound assessment.
In another case study, although procedure manuals were not formalised, Subject Persons were still implementing a number of AML/CFT measures, thus adequately complying with their CDD and other obligations.