Strengthening Compliance: Introducing ACS Operations’ UK-Compliant Corporate Customer Risk Assessment Framework

At ACS Operations, we know that effective risk management and regulatory compliance start with real-world experience. Partnering with a leading UK-based financial institution, we have developed and implemented a bespoke Corporate Customer Risk Assessment Framework. This framework is fully aligned with UK and global regulatory standards, including the Financial Conduct Authority (FCA) Handbook, Joint Money Laundering Steering Group (JMLSG) Guidance, Money Laundering Regulations 2017 (as amended), and Financial Action Task Force (FATF) recommendations.

Designed to enhance regulatory compliance, our framework delivers a structured, risk-sensitive approach to corporate customer classification. Whether your institution requires managed services, strategic advisory, compliance assurance, KYC remediation, or specialist recruitment, ACS Operations has the expertise to support you across the First, Second, or Third Lines of Defence.

Corporate Customer Risk Assessment Framework (UK-Compliant Version)

Purpose

Our proposed framework offers a structured, risk-based methodology for assessing corporate customer risk. Financial institutions are able to adjust scoring thresholds, data inputs, and weightings to align with their own risk appetite and business model, while fully adhering to UK regulatory obligations and international best practice.

Risk Classification and Scoring

Customers are categorised based on their total risk score:

• Low Risk: 0–35 points

• Medium Risk: 36–55 points

• High Risk: 56–100 points

• Prohibited: Over 100 points or where Red Flag criteria are triggered

Risk Indicators and Suggested Weights

1. Length of Business

• >24 Months: Low Risk

• 13–24 Months: Medium Risk

• 0–12 Months: High Risk

2. Sector / Industry Risk

(Aligned with JMLSG Guidance)

• Regulated Industries (e.g., insurance, banking): Low Risk

• Moderate Risk Industries (e.g., fintech, gaming): Medium Risk

• High Risk Industries (e.g., crypto, MSBs, shell companies): High Risk

3. Jurisdiction / Country Risk

(Aligned with FATF and FCA Guidance)

• FATF-compliant / UK Equivalent Jurisdictions: Low Risk

• Under Monitoring / Emerging Risk Jurisdictions: Medium Risk

• High-Risk / Non-Cooperative Jurisdictions: High Risk

• Sanctioned Jurisdictions: Prohibited

4. Politically Exposed Persons (PEPs)

(According to FCA and JMLSG Guidance)

• No PEP: Low Risk

• Domestic PEP / Immediate Family: Medium Risk

• Foreign Senior Official / Prominent Function: High Risk

5. Adverse Media / Reputation

• Clean / Non-Material Allegations: Low Risk

• Moderate Allegations / Unverified Reports: Medium Risk

• Confirmed Criminal / Regulatory Risk: High Risk

6. Ownership and Control Complexity

(Aligned with MLR 2017 Regulations 5 & 28)

• Simple / Transparent Beneficial Ownership Structures: Low Risk

• Complex Structures (e.g., multiple layers, offshore entities, bearer shares): High Risk

7. Product / Transaction Profile

• Standard Payments / Lending: Low Risk

• Third-Party / Cross-Border Transactions: Medium Risk

• Crypto Services / High-Risk Financial Products: High or Prohibited Risk

Tailored Compliance Support Starts Here

In today’s fast-changing regulatory environment, a structured and risk-sensitive customer risk assessment framework is crucial to maintaining compliance and preventing financial crime. At ACS Operations, we specialise in developing, tailoring, and operationalising these frameworks across a wide range of financial sectors.

If you would like to discuss how we can support your institution’s compliance objectives and strengthen your anti-money laundering defences, please get in touch

Contact details

Address

1 Montpelier Avenue, London, England, W5 2XP

Email

info@acsoperations.com

Phone Number

020 3633 0203