CDD

Customer Risk Assessment

GFSC 4-category risk assessment (Customer, Product, Country, Interface) with sanctions/adverse media checks, EDD triggers, and business/guarantor logic.

0) Assessment Header
Use “Online portal / digital onboarding” for non-face-to-face onboarding.
1) Assessment Type & Loan Details
Business Loan auto-switches document requirements.
EDD auto-flags if amount > £10,000.
If checked, guarantor sections will appear below.
2) Customer Details
3) Documents & Review
Tick “Provided”, then tick the checks completed, then add reviewer notes. Table adapts for Business Loans.
Document ProvidedChecks Completed (tick)Reviewer Notes
4) Sanctions Screening & Adverse Media Screening (Customer)
If “No”, escalate to MLRO before onboarding / drawdown.
5) Risk Assessment (GFSC categories)
Score each category 1–5 (1 = Low, 5 = High). Keep each rationale/mitigation short and clear.
Risk CategoryScore (1–5)RationaleMitigating Controls
Customer Risk
Identity, employment, behaviour, BOP (if applicable)
Product Risk
Amount, term, purpose, disbursement
Country Risk
Residence, employer, bank account, cross-border
Interface Risk
Channel, non-F2F, uploads, missing docs
Tip: If sanctions not clear or adverse media confirmed, escalate and consider High.
6) Recommendation