arms manufacturing/supply and the defence industry Clearly not all work in these sectors will be higher risk but it is essential to be aware of the potential for risk so that you can implement proportionate procedures for closer scrutiny on client and matter acceptance. 2.3.1.4 Acting for politically exposed persons (PEPs) An independent legal professional’s exposure to PEPs is also a major consideration in carrying out your practice-wide risk assessment. A PEP may be a client or a beneficial owner of a client but it is important to consider the type of PEPs that you act for and whether the work to be undertaken will affect your overall risk profile. PEPs are considered in section 4.12.2. 2.3.1.5 Acting for clients without meeting them In an increasingly global and technologically advanced environment, it is commonly the case that you will act for clients without meeting them. You should include this as a factor when you out your practice-wide risk assessment. In addition, you should consider the systems and procedures that you have implemented to mitigate the risks associated with acting for clients you do not meet. When you act for clients without meeting them you must be satisfied that it sense in all the circumstances that you have not met the client and you must be comfortable that you can mitigate the risks of identity fraud. 2.3.1.6 Clients with high cash turnover businesses You should consider whether your practice frequently acts for clients who operate or benefit from high cash turnover businesses as these businesses may be appealing to criminals seeking to launder money. 2.3.2 Services and of law and geographical location of services provided In carrying out your practice-wide risk assessment you must consider risks associated with the services you provide, the transactions you participate in and the countries or geographic areas in which you operate. 2.3.2.1 Services and areas of law Many studies have highlighted that independent professionals face the greatest potential risks in the following areas: misuse/abuse of client accounts sale/purchase of real property creation of trusts, companies and charities management of trusts and companies sham litigation
arms manufacturing/supply and the defence industry Clearly not all work in these sectors will be higher risk but it is essential to be aware of the potential for risk so that you can implement proportionate procedures for closer scrutiny on client and matter acceptance. 2.3.1.4 Acting for politically exposed persons (PEPs) An independent legal professional’s exposure to PEPs is also a major consideration in carrying out your practice-wide risk assessment. A PEP may be a client or a beneficial owner of a client but it is important to consider the type of PEPs that you act for and whether the work to be undertaken will affect your overall risk profile. PEPs are considered in section 4.12.2. 2.3.1.5 Acting for clients without meeting them In an increasingly global and technologically advanced environment, it is commonly the case that you will act for clients without meeting them. You should include this as a factor when you out your practice-wide risk assessment. In addition, you should consider the systems and procedures that you have implemented to mitigate the risks associated with acting for clients you do not meet. When you act for clients without meeting them you must be satisfied that it sense in all the circumstances that you have not met the client and you must be comfortable that you can mitigate the risks of identity fraud. 2.3.1.6 Clients with high cash turnover businesses You should consider whether your practice frequently acts for clients who operate or benefit from high cash turnover businesses as these businesses may be appealing to criminals seeking to launder money. 2.3.2 Services and of law and geographical location of services provided In carrying out your practice-wide risk assessment you must consider risks associated with the services you provide, the transactions you participate in and the countries or geographic areas in which you operate. 2.3.2.1 Services and areas of law Many studies have highlighted that independent professionals face the greatest potential risks in the following areas: misuse/abuse of client accounts sale/purchase of real property creation of trusts, companies and charities management of trusts and companies sham litigation