AMLG11210 | Guidance for all sectors: Additional considerations for businesses using agents or branches

12.1 Additional considerations for businesses using agents or branches

If you are a business that uses agents, when conducting your risk assessment, you should consider this (non-exhaustive) list of questions to help inform your risk assessment and consequently your PCPs:

• How will you apply risk management procedures to the network of agents or branches?

• How will you manage and maintain records, for example, if the branch closes or you end your relationship with an agent?

• If you selected a number of customer files at random, would they all have a risk assessment and adequate customer due diligence records in connection with the customers and beneficial owners, and would ongoing monitoring support your original risk assessment?

• If you have applied simplified due diligence, will your records evidence the decision to treat the customer as low risk in line with your risk assessment?

• Do you have a system that will pick up where individuals, departments, branches or agents are not implementing risk management procedures?

• Could you demonstrate that all staff, including those employed by your agents, have been trained on the Regulations and the business’s PCPs and been given ongoing training on recognising and dealing with suspicious transactions?

• If asked, will staff at your branches and your agents know who the nominated officer is, what the firm’s policies are and where they can be found?

Some of the additional risk factors that could arise in businesses that use agents and should be addressed in your risk assessment and PCPs are as follows:

• Agents sharing log in details.

• Agents providing multiple services or acting for multiple principals.

• Agents self-sending.