Compass
Assessments
Process · Retail client onboarding

AML & KYC — Retail OnboardingActive

Compliance risk assessment of the retail client onboarding process, covering CDD, sanctions and monitoring.

R-1001

Incomplete customer due diligence

Clients are onboarded without complete identification, verification of beneficial owners, or a documented risk classification.

Financial CrimeClient OnboardingAMLD6 Art. 13CSSF 12-02
Impact
Severe
Likelihood
Likely
Inherent
High
Residual
Medium

Mitigating controls (2) · Owner: Marc Lefèvre

  • C-5001Four-eye review of onboarding files
    Preventive · Semi automated · At time of event
    Weight 0.6Effective
  • C-5002Enhanced due diligence for high-risk clients
    Preventive · Manual · At time of event
    Weight 0.4Partially effective
R-1002

Onboarding of sanctioned parties

A sanctioned individual or entity, or a party owned or controlled by one, enters a business relationship undetected.

Financial CrimeSanctionsEU Reg. 269/2014
Impact
Very severe
Likelihood
Unlikely
Inherent
High
Residual
Low

Mitigating controls (1) · Owner: Claire Dubois

  • C-5003Daily sanctions list screening
    Detective · Automated · Daily
    Weight 1Strong
R-1003

Suspicious transactions not escalated

Unusual transaction patterns are not detected or alerts are closed without adequate investigation and SAR filing.

Financial CrimeTransaction MonitoringAMLD6 Art. 18
Impact
Severe
Likelihood
Likely
Inherent
High
Residual
Medium

Mitigating controls (1) · Owner: Marc Lefèvre

  • C-5004Transaction monitoring alert review
    Detective · Semi automated · Weekly
    Weight 1Effective