Customer risk assessment

Customer risk assessment based on the risk factors of Annex 2 of the Czech AML Act: answer questions on the customer, countries, transaction and channel and get a reasoned risk level, required measures and text for the AML form. Free; answers stay in your browser.

Answers stay in your browser only. Nothing is sent to our server; save the result as a PDF or to the client case in this browser.

Customer and structure

A sanctions match for the customer or a related person could not be ruled out
The customer, beneficial owner or acting person is a PEP or a close associate or family member
The customer avoids giving information, details conflict or the source of funds is not documented
Complex or opaque ownership; the beneficial owner cannot be reliably identified
Nominee shareholders or directors, bearer shares or representation without a clear reason
Adverse information about the customer or related people (media, registers, criminal proceedings)
Insolvency, liquidation or unreliable VAT payer status
Cash-intensive business (hospitality, used cars, exchange, gaming…)
Newly founded company (under 12 months), shelf company or recent change of owners

Countries

The customer, owner or transaction is linked to an EU high-risk third country
Link to a country under increased FATF monitoring (grey list)
Link to a country under an EU or UN sanctions regime
The customer or beneficial owner is based outside the EU/EEA

Transaction and payments

Unusual or complex transaction without an apparent economic or lawful purpose
Significant cash payments or split payments
Payments from third parties or to accounts unrelated to the customer
Transaction value does not match the customer’s profile and income
Product or service favours anonymity (crypto-assets, bearer securities, intermediaries)

Delivery channel

The customer was not present and remote identification did not use Bank iD or another lawful method

Lower-risk factors

Optional. They lower the score but never remove mandatory enhanced due diligence.

The customer is a public authority or public body in the EU
The customer is listed on a regulated market with ownership disclosure duties
Long-standing customer with known, transparent activity and no past suspicion
Routine recurring low-value service (e.g. bookkeeping for a small business)

How it works

  1. Answer Yes, No or Unknown for each factor. Part of the answers is prefilled from the case file.
  2. Follow the live result: risk level, mandatory enhanced due diligence and recommended measures.
  3. If you disagree, adjust the level and give your reason.
  4. Download the PDF and prepare the text for the internal part of the AML form.

What it covers

  • 19 risk factors for customer, countries, transaction and channel
  • Lower-risk factors
  • Mandatory enhanced due diligence for PEPs and EU high-risk countries (Section 9a)
  • Stopping the business on an open sanctions match
  • A reasoned manual adjustment of the level

What it does not cover

  • Your firm-wide risk assessment (Section 21a) – there is a separate template
  • Deciding for the obliged entity – the result is a reasoned basis
  • Simplified due diligence – low risk alone does not allow it

Common questions

When is enhanced due diligence mandatory?

Among others for politically exposed persons and links to an EU high-risk third country (Section 9a). In the tool these always lead to high risk regardless of the score and cannot be lowered manually.

Why does “Unknown” count towards the risk?

An unresolved circumstance is not a “no”. It counts at half the factor’s weight until verified and is listed as unresolved.

How does this differ from the firm-wide risk assessment?

The obliged entity’s risk assessment (Section 21a) covers your whole business and is part of your internal rules. The customer risk assessment covers one customer and transaction. You need both.

Where are the answers stored?

Only in your browser – in the client case if you use one, or as a prepared text for the form for 24 hours. Nothing is sent to the server.