ABSTRACT
The challenge of de-risking intersects legislation, guidance, and enforcement action opinions issued by global regulators, bank reputation risk, and financial crime compliance programmes. The Customer Risk Assessment is one of a suite of risk assessments that must be performed by a bank to comply with its Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) regulations. Directors and Trustees should understand the role that legal entity type can play in any High Risk Customer rating or de-risking decision. AML/CTF programmes incorporate the risk rating of countries based on a variety of political, social, economic, and legal factors identified by each bank for this purpose. International Non-Governmental Organisations (INGO), particularly those conducting activity perceived to be high-risk or which operate in high-risk jurisdictions, should be particularly attuned to the nature and tone of any communications from their bank. Bank stakeholder management is particularly important for INGOs operating higher risk business activities in ‘high-risk’ jurisdictions.
