completed within 14 days after the day on which the transaction occurred. As well you are to use the forms to verify identity of these clients. insurers’ Risk-mitigation examples Risk Assessment Clientele profile Yes No N/A Risk-mitigation steps L = Low M = Moderate H = High Politically exposed X L I do not have any clients at this time who are foreign persons? politically exposed persons, either foreign or domestic; however, as outlined in my policies and procedures I take reasonable measures to determine if a person is a politically exposed. If the determination is made I verify identification using forms and monitor client transactions every insurers’ six months. Politically exposed X L I have few clients who are politically exposed foreign foreign persons? forms used to verify identity of persons. Insurers’ these clients. Transactions for these clients monitored semi-annually. Politically exposed X H 20% of clients associated with my practice are foreign persons? politically exposed persons, both foreign and domestic. forms used to verify identity of Insurers’ these clients. Client files are flagged to ensure quarterly monitoring of transactions. Is the client a X I do not have any clients at this time who own their cash-intensive own business. Procedures in place to verify business identification if business owners become clients. Is the client a X I have few clients who are business owners in cash-intensive businesses. Two mini-mart owners and one business vending machine business owner. forms Insurers’ used to verify identity and transactions clients’ monitored semi-annually to ensure consistent investment deposits. Is the client a X My niche market is made up of small business cash-intensive owners. Approximately 40% accept cash and of business those 10% would qualify as cash-intensive business. I verify identification forms and a using insurers’
completed within 14 days after the day on which the transaction occurred. As well you are to use the insurers’ forms to verify identity of these clients. Risk-mitigation examples Clientele profile Yes No N/A Risk Assessment L = Low M = Moderate H = High Risk-mitigation steps Politically exposed foreign persons? X L I do not have any clients at this time who are politically exposed persons, either foreign or domestic; however, as outlined in my policies and procedures I take reasonable measures to determine if a person is a politically exposed. If the determination is made I verify identification using insurers’ forms and monitor client transactions every six months. Politically exposed foreign persons? X L I have few clients who are politically exposed foreign persons. Insurers’ forms used to verify identity of these clients. Transactions for these clients monitored semi-annually. Politically exposed foreign persons? X H 20% of clients associated with my practice are politically exposed persons, both foreign and domestic. Insurers’ forms used to verify identity of these clients. Client files are flagged to ensure quarterly monitoring of transactions. Is the client a cash-intensive business X I do not have any clients at this time who own their own business. Procedures in place to verify identification if business owners become clients. Is the client a cash-intensive business X I have few clients who are business owners in businesses. Two mini-mart owners and one vending machine business owner. Insurers’ forms used to verify clients’ identity and transactions monitored semi-annually to ensure consistent investment deposits. Is the client a cash-intensive business X My niche market is made up of small business owners. Approximately 40% accept cash and of those 10% would qualify as cash-intensive business. I verify identification using insurers’ forms and a
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