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  • Product/Service/Transactions risk

    • FC-C.2.7

      An overall risk assessment should include determining the potential risks presented by product, service, transaction or the delivery channel of the insurance licensee. A licensee should assess, using a RBA, the extent to which the offering of its product, service, transaction or the delivery channel presents potential vulnerabilities to placement, layering or integration of criminal proceeds into the financial system.

      Added: January 2022

    • FC-C.2.8

      Determining the risks of product, service, transaction or the delivery channel offered to customers may include a consideration of their attributes, as well as any associated risk mitigation measures. Products and services that may indicate a higher risk include:

      (a) Anonymous transactions (which may include cash);
      (b) Non-face-to-face business relationships or transactions;
      (c) Payment received from unknown or un-associated third parties;
      (d) Products or services that may inherently favour anonymity or obscure information about underlying customer transactions;
      (e) The geographical reach of the product or service offered, such as those emanating from higher risk jurisdictions;
      (f) Products with unusual complexity or structure and with no obvious economic purpose;
      (g) Products or services that permit the unrestricted or anonymous transfer of value (by payment or change of asset ownership) to an unrelated third party, particularly those residing in a higher risk jurisdiction; and
      (h) Use of new technologies or payment methods not used in the normal course of business by the insurance licensee.
      Added: January 2022