A complete Risk-Based Approach (RBA) framework aligned to FATF Recommendations — covering customer, geography, product, channel and industry risk, with heat-maps that go straight to the board.
The Risk-Based Approach was first proposed by the FCA in 2000 and adopted by the FATF in 2007. It has since been embraced by the Wolfsburg Group, IOSCO and most national regulators.
The RBA is the recognition that AML controls should be calibrated to the risk perception, appetite and customer risk profile of the institution — not applied uniformly. Done well, it focuses your scarce compliance resources where they create the most value.
Define and catalogue every risk factor relevant to your business.
Quantify the level of risk attached to each factor.
Map the impact of each risk on the institution.
Apply controls, monitor effectiveness and review.
Background, AML system checks and political affiliations (PEPs).
Country of residence and country of incorporation.
Account/facility type, currency and previous banking relationship.
Nature of business activity and related activities.
The LiveEx Risk-Based Framework is aligned with the FATF Recommendations (adopted 2012). At its centre is a heat-map — a snap-shot visual display of risk status that goes straight to senior managers and the Board, no spreadsheets required.
An in-built Risk Mitigation form (extended version) supports assessment of preventative measures, control strength and audit functions — at the group level. Mitigation actions are tied back to the risks they address, so nothing falls between the cracks.
Profile, history, ownership and beneficial-owner risk.
Country of operation, residence and incorporation.
Risk attached to the products and channels involved.
LiveEx assesses residual risk across four bands — Low, Medium, Medium High and High — taking into account both inherent risk and the strength of mitigating controls. The MLRO customises the framework per business, and the system generates the residual risk score with a periodic review schedule attached.