ASSESSMENT CRITERIA
RISK LEVEL
SCORE
A. Money laundering risk
I. Risk of money laundering from the business environment of the reporting entity
1. Risk of money laundering from the industry or sector in which the reporting entity operates
4
2. Risk of money laundering from the country or jurisdictions in which the reported entity operates
5
II. Risk of money laundering from business activities
1. Risk of money laundering from customers
2
2. Risk of money laundering from products and services provided to customers
1
3. Risk of money laundering from the way products and services are distributed
3.1 Evaluate bank's transaction channels
4
3.2 Evaluate 3rd-party transacion channels
4
B. The level of compliance with the internal AML policies and regulations
I. Comprehensiveness of internal policies and regulations on AML
1. The adequacy of internal policies and regulations on AML
4
2. The level of compliance with AML legislation
4
3. The level of consistency with the level of money laundering risk of the reporting entity
4
4. The periodic re-evaluation of internal policies to comly with changes in law or regulations and operational practices
4
II. The effectiveness of the implementation of internal policies and regulations on AML
1. The efficiency of implementation of AML measures
1.1 Availability of compliance system and reporting
3
1.2 STR report information
3
1.3 Accuracy of CTR, DWT, EFT Report
3
2. The level of understanding, compliance with rules and professional standards of leaders and employees with relevant responsibilities for AML
2.1 Quality of training program
3
2.2 Results of training sessions
3
2.3 Ratio of trained staff
3
2.4 Group of trained staff
3
3. The level of efficiency of AML management.
3.1 Errors in operation (SBV, Internal Audit)
3
3.2 The extent to which problems detected by internal audit or external parties have been remedied
3
3.3 Automation level (software application)
3
