On 17 August, HMRC published risk assessment information provided to trust or company service providers under the Money Laundering Regulation to assist relevant persons in carrying out their own money laundering and terrorist financing risk assessment. In introduction its says that the UK National Risk Assessment 2017 assessed Trust and Company Service Providers (TCSP) as posing a relatively high risk, that risk increasing when provided with other financial, legal or accountancy services. TCSP outside of these sectors are assessed as medium risk for money laundering, and low for terrorist financing.  It says that it is important that businesses understand and properly appraise the risk presented by each customer or class of customer and properly reflect this in their risk assessment; and that a business puts in place policies, controls and procedures to assess and address the varying level of risks presented by their customers.  A table lists risk characteristics and comments for each.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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