Useful risk guidance [for all] in the JFSC NPO AML guidance handbook [section 17]
10/01/2023
In section 17 [PRESCRIBED NON-PROFIT ORGANISATIONS] of the JFSC Handbook for the prevention and detection of money laundering, the countering of terrorist financing,and the countering of proliferation financing [DATED : 1 January 2023] te following risk guidnace notes and images were publisehed.
Although the following has been published in only section 17 for NPOs the guidance can be used as a steer/guide for all AML regulated persons.
THE RISK ASSESSMENT CYCLE
Risk monitoring is a dynamic and cyclical process. It ensures that any new risks are addressed as they arise and establishes how previously identified risks may have changed.
The below diagram from the JFSC Handbook and has copied the UK Charities Commission illustrates the risk assessment cycle:
Read more here –
PROGRAMME RISK ASSESSMENT (PRA)
A risk-based approach can be established through the completion of a programme risk assessment (PRA)
An example of a NPO PRA checklist can be downloaded from the JFSC website and modified, as appropriate: draft programme risk assessment checklist.
This template is not intended to be rigid or prescriptive. A NPO may wish to make amendments to the checklist to account for the specific risks relevant to its activities.
READ MORE HERE
DIVERSION RISK
A Prescribed NPO must define and document their approach to Diversion risk in a risk appetite
Statement
A Prescribed NPO may demonstrate they are adequately monitoring risk by keeping records of
their monitoring activities in a Diversion risk register.
An example of a Diversion risk register can be downloaded from the JFSC website: and as shown below .
READ MORE HERE
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.