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1. 1. Introduction: Overview of the purpose of the risk assessment and regulatory context
2. 2. Firm Information: Details of the estate agency, including size, structure, and services offered
3. 3. Methodology: Explanation of the risk assessment approach, scoring system, and frequency of reviews
4. 4. Business Risk Assessment: Analysis of firm-wide risks including customer base, services, geographical exposure, and delivery channels
5. 5. Customer Risk Factors: Assessment of different customer types and associated risks
6. 6. Geographic Risk Factors: Analysis of geographical risks in areas where the firm operates or has clients
7. 7. Service and Transaction Risk Factors: Evaluation of risks associated with different property services and transaction types
8. 8. Delivery Channel Risk Factors: Assessment of risks related to how services are delivered (in-person, online, through intermediaries)
9. 9. Control Measures: Description of AML controls implemented to mitigate identified risks
10. 10. Risk Matrix: Overall risk scoring and categorization framework
11. 11. Monitoring and Review: Procedures for ongoing monitoring and periodic review of the risk assessment
1. International Operations: Required if the estate agency operates in multiple jurisdictions or handles international clients
2. Digital Services Risk Assessment: Needed if the firm offers online or virtual property services
3. High-Value Property Procedures: Required for agencies dealing with luxury or high-value properties
4. Corporate Client Procedures: Necessary if dealing with corporate clients or complex ownership structures
5. Staff Training Program: Detailed section on training if the firm has multiple employees or departments
1. Appendix A - Risk Assessment Ƶ: Standard templates for conducting individual client risk assessments
2. Appendix B - Customer Due Diligence Checklists: Checklists for different customer types and risk levels
3. Appendix C - Risk Scoring Matrix: Detailed scoring criteria and methodology
4. Appendix D - Red Flag Indicators: List of suspicious activity indicators specific to real estate
5. Appendix E - Document Verification Requirements: Guidelines for verifying different types of identification documents
6. Appendix F - Screening Procedures: Procedures for PEP and sanctions screening
7. Appendix G - Reporting Forms: Ƶ for internal suspicious activity reporting
8. Appendix H - Review Log: Template for documenting periodic reviews and updates
Real Estate
Property Management
Property Development
Financial Services
Legal Services
Compliance and Regulatory
Professional Services
Property Investment
Compliance
Risk Management
Legal
Operations
Senior Management
Property Sales
Property Lettings
Customer Due Diligence
Internal Audit
Board of Directors
Compliance Officer
Money Laundering Reporting Officer (MLRO)
Estate Agent
Property Manager
Managing Director
Risk Manager
Operations Director
Branch Manager
Senior Property Consultant
AML Specialist
Compliance Manager
Property Services Director
Chief Risk Officer
Board Member
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