CLIENT NAME:

CLIENT REFERENCE:

Kno
Client trading name (if different to registered name);
PLEASE DO NOT DE

Nature of the client’s business;

Company and VAT registration numbers (if applicable);

Country/countries client registered and operating in;

Full names of all beneficial owners, partners, directors, Trustees

and/or Settlors;

Home address(es);

Registered office address(es);

Client contact telephone number(s);

Client email address(es);

Client website;

Structure of client (if commercial entity) including shares/ownership

breakdown;

Number of years client has been trading;

Previous financial years turnover (if applicable);

Projected turnover for next financial year;

Number of employees;

How was the client introduced to the practice?

Any other information or comments? If you n

Know

Have all beneficial owners/partners/directors photo ID and proof of

addresses been obtained, and copies retained on file?
Where necessary have reasonable steps been taken to verify
beneficial ownership?

Has a search of the beneficial ownership Register been undertaken

and is it consistent with our understanding of the beneficial owners.?

Has a certificate of incorporation/partnership agreement/trust deed

been obtained? If so, has a copy been retained on file?

Have financial records from the client’s previous accountant been

obtained and are all the client’s tax affairs up to date? If yes, have
copies been retained on file?

Has Companies Registration Office/Companies House been consulted

to confirm that information provided by the client corresponds with
information held on the public register?

Who are the client’s key stakeholders?

Has an open source adverse media search been completed online?

Has it been verified if the client has any significant overseas interests
or operations?

Has a reasonable risk-based approach been taken in relation to

sanctions screening?

<ADDITIONAL QUESTION1> If you n

CL
CLIENT RISK

Is the client a politically exposed person? (Politically exposed persons, PEPs, are individuals whose prominent position in public life ma
extends to immediate family members and known close associates).
Do you have full visibility and knowledge of the ultimate beneficial owners’ and/or all directors?
Is the client a high-net-worth individual? (e.g. assets of €1m/£1m or more)
Does the client or its beneficial owners have attributes known to be frequently used by money launderers or terrorist financiers? (e.g.
complex?)
Has evidence/documents proving source of wealth and funds been provided?
Has the client provided proof of identification and proof of address?
Has the client been evasive or uncooperative? (e.g. appeared reluctant to provide ID)
Is the client a public administration, or a publicly owned enterprise?
Is the client/firm securities listed on a regulated market?
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
GEOGRAPHIC RISK
Is the client/firm based within close proximity of our firm? (e.g. within 10 miles).
Is the client based outside of Ireland?
Does the client have any association with a Sanctioned jurisdictions? (e.g. does the client transact with customers in sanctioned jurisdi
to sanctions?)

Does the client have any association with any geographical areas that are considered to have weak AML and Terrorist Financing contro
listed on the 'FATF High-risk and other monitored jurisdictions' or the 'European Commission list of third countries with weak AML and
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
SERVICE RISK
Will the client be using our client money account?
Will we be providing trust or company services for the client? (This includes company formation and use of our address for correspond
Is the business relationship between you and the client logical and practicable? (For example, Is the size of the firm’s business proporti
within the accountancy firms areas of expertise?)
Is it understood why the client has come to use our services? (e.g. referred by an existing client)
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
INDUSTRY RISK
Would the client be typically considered a cash intensive business? (e.g. restaurants, retail outlets etc.)
Does the client deal with high value goods? (e.g. jewellers, car dealerships, properties etc.)

Does the client operate in an industry typically considered high-risk of money laundering or terrorist financing? (e.g. money services b
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
DELIVERY CHANNEL RISK
Have you met the client face to face?
<ADDITIONAL QUESTION1>

Use this section to summarise the client risks and any further comments

NOTE: This client risk assessment is to be conducted at the on-

Initial assessment of risk: Medium

Final assessment of risk:
Notes: (if there is any reason to override the initial assessment risk
score it should be stated here)

Conducted by:
Agreed by:

Next date of review:

 Know Your Client (KYC) - Onboarding Form
PLACE COMMENTS/NOTES IN THIS SECTION.
PLEASE DO NOT DELETE ANY ROWS AS IT MAY CAUSE FORMULA ISSUES LATER IN THE DOCUMENT; EITHER AMEND THE QUESTION, LEAV

i.e. partnership, limited company or LLP etc

If you need to add additional questions, ensure you use the 'Insert Row' function. If not, you may cause an error with the form

Know Your Client (KYC) – Onboarding Checklist

State the names of each individual whose identity has been verified and confirm what form of ID and proof of add
 E.g. have share certificates/partnership agreements etc been obtained and retained on file?

The Fifth Money Laundering Directive obliges accountants to report any discrepancies to Companies House at the
https://www.gov.uk/guidance/report-a-discrepancy-about-a-beneficial-owner-on-the-psc-register-by-an-o

i.e. suppliers, overseas partners and other associated business partners?

Detail any relevant findings here.

It is advised that all clients are screened at onboarding.

If you need to add additional questions, ensure you use the 'Insert Row' function. If not, you may cause an error with the form

CLIENT RISK ASSESSMENT - Onboarding

Yes or No?

ent position in public life may make them vulnerable to corruption. The definition
No
Yes
No
or terrorist financiers? (e.g. is the structure of the customer is unusual or excessively
No
Yes
Yes
No
No
No
N/A
N/A
N/A
K Yes or No?
Yes
No
stomers in sanctioned jurisdictions or have operations or trade with jurisdictions subject
No

nd Terrorist Financing controls? (e.g. does the client transact with customers in countries
ountries with weak AML and terrorist financing regimes?) No
N/A
 N/A
N/A
Yes or No?
No
of our address for correspondence). No
f the firm’s business proportionate to the accountancy firm? Is the client’s business
Yes
Yes
N/A
N/A
N/A
Yes or No?
No
No

cing? (e.g. money services business, import/export, charities etc.) No

N/A
N/A
N/A
RISK Yes or No?
Yes
N/A
NOTES

be conducted at the on-boarding process and part of its on-going monitoring. It should also be updated if there have been

Date:
Date:
Form
OTES IN THIS SECTION.
CUMENT; EITHER AMEND THE QUESTION, LEAVE BLANK OR HIDE THE ROW IF NOT NEEDED.

ed company or LLP etc

on. If not, you may cause an error with the formulas further on in the document.

hecklist

d and confirm what form of ID and proof of address has been taken.
ements etc been obtained and retained on file?

ort any discrepancies to Companies House at the following address;

-a-beneficial-owner-on-the-psc-register-by-an-obliged-entity

d other associated business partners?

ant findings here.

are screened at onboarding.

on. If not, you may cause an error with the formulas further on in the document.

ing
Additional comments

Additional comments
 Additional comments

Additional comments

Additional comments

ould also be updated if there have been any significant changes.

 CLIENT NAME: 0

CLIENT REFERENCE: 0

Know Your Client (KYC) - On-goin

Has the client’s registered name or trading name changed since the
client was on-boarded or last reviewed? PLEASE DO NOT DELETE ANY ROWS AS IT MAY CAUSE FO

Has the nature of the client’s business changed since the client was
on-boarded or last reviewed?

Has there been any change in the client’s company or VAT

registration numbers since the client was onboarded or last
reviewed?

Has the country the client is registered in and operating in changed

since the client was onboarded or last reviewed?

Has there been any change of

owners/partners/directors/Trustees/Settlors since the client was on-
boarded or last reviewed?

Has the client’s registered address changed since the client was
onboarded or last reviewed?

Has the client’s contact telephone number changed since the client
was onboarded or last reviewed?

Has the client’s email address changed since the client was
onboarded or last reviewed?

Has the client’s website changed since the client was onboarded or
last reviewed?

Has the client’s structure (if commercial entity i.e. a limited company
or partnership) changed since the client was on-boarded or last
reviewed?

Have there been any changes in share ownership since the client was
on-boarded or last reviewed?

Previous financial year turnover;

Projected turnover for next financial year;

Any other information or comments? If you need to add additional questions, ensu

Know Your Client (KYC) – On-going

 Know Your Client (KYC) – On-going

Are all beneficial owners/partners/directors photo ID’s and proof of

addresses up to date, with copies retained on file?

Has the photo ID and proof of address of all newly appointed owners,
partners, directors, Trustees and/or Settlors been obtained with
copies retained on file?

Has it been determined whether the beneficial owners has changed

since the client was onboarded or last reviewed? You must a

If there has been any change in the client’s structure, has the
corresponding documentation such a partnership agreement or
certificate of incorporation been obtained, and a copy retained on
file?

Has Companies House been recently consulted to confirm that

information provided by the client corresponds with information held The Fifth Money Laundering Dir
on the public register? https://www.gov.uk/guid

Has there been any change in the client’s key stakeholders since the i.
client was on-boarded or last reviewed?
Has an open source adverse media search been recently completed
online?
Has it been recently verified if the client has any significant overseas
interests or operations?

Has a reasonable risk-based approach been taken in relation to

sanctions screening?

<ADDITIONAL QUESTION1> If you need to add additional questions, ensu

CLIENT RISK ASSESS

CLIENT RISK

Is the client a politically exposed person? (Politically exposed persons, PEPs, are individuals whose prominent position in public life ma
extends to immediate family members and known close associates).
Do you have full visibility and knowledge of the ultimate beneficial owners’ and/or all directors?
Is the client a high-net-worth individual? (e.g. assets of £1m or more)
Does the client or its beneficial owners have attributes known to be frequently used by money launderers or terrorist financiers? (e.g.
complex?)
Has evidence/documents proving income been provided? (e.g. invoices/bank statements)
Is the proof of identification and proof of address held on file valid and up-to-date?
Has the client been evasive or uncooperative? (e.g. appeared reluctant to provide ID)
Is the client a public administration, or a publicly owned enterprise?
Is the client/firm securities listed on a regulated market?
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
GEOGRAPHIC RISK
Is the client/firm based within close proximity of our firm? (e.g. within 10 miles).
Is the client based outside of Ireland?
Does the client have any association with a Sanctioned jurisdictions? (e.g. does the client transact with customers in sanctioned jurisdi
to
Doessanctions?)
the client have any association with any geographical areas that are considered to have weak AML and Terrorist Financing contro
listed on the 'FATF High-risk and other monitored jurisdictions' or the 'European Commission list of third countries with weak AML and
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
SERVICE RISK
Has, or will, the client be using our client money account?
Will we be providing trust or company services for the client? (This includes company formation and use of our address for correspond
Is the business relationship between you and the client logical and practicable? (For example, Is the size of the firm’s business proporti
within the accountancy firms areas of expertise?)
Is it understood why the client has come to use our services? (e.g. referred by an existing client)
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
INDUSTRY RISK
Would the client be typically considered a cash intensive business? (e.g. restaurants, retail outlets etc.)
Does the client deal with high value goods? (e.g. jewellers, car dealerships, properties etc.)
Does the client operate in an industry typically considered high-risk of money laundering or terrorist financing? (e.g. money services b
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
DELIVERY CHANNEL RISK
Have we ever met the client face-to-face?
<ADDITIONAL QUESTION1>
NOT
Use this section to summarise the client risks and any further comments

NOTE: This client risk assessment is to be conducted at the on-boarding process and part of it

Review of assessment of risk: Medium

Notes: (if there is any reason to override the initial assessment risk score it should
be stated here)

Conducted by:
Next date of review:
KYC) - On-going Monitoring Form - 1st Review
PLACE COMMENTS/NOTES IN THIS SECTION.
Y ROWS AS IT MAY CAUSE FORMULAR ISSUES LATER IN THE DOCUMENT; EITHER AMEND THE QUESTION, LEAVE BLANK OR HIDE THE ROW IF NOT N

d additional questions, ensure you use the 'Insert Row' function. If not, you may cause an error with the formulas further on in the document.

YC) – On-going Monitoring Checklist - 1st Review

YC) – On-going Monitoring Checklist - 1st Review

If not, please give full details of action taken.

You must also consider beneficial owners that are not individuals (e.g. a limited company).

Fifth Money Laundering Directive obliges accountants to report any discrepancies to Companies House at the following address;
https://www.gov.uk/guidance/report-a-discrepancy-about-a-beneficial-owner-on-the-psc-register-by-an-obliged-entity

i.e. suppliers, overseas partners and other associated business partners.

d additional questions, ensure you use the 'Insert Row' function. If not, you may cause an error with the formulas further on in the document.

NT RISK ASSESSMENT - 1st Review

Yes or No?

ent position in public life may make them vulnerable to corruption. The definition
No
Yes
No
or terrorist financiers? (e.g. is the structure of the customer is unusual or excessively
No
Yes
Yes
No
No
No
N/A
N/A
N/A
K Yes or No?
Yes
 No
stomers in sanctioned jurisdictions or have operations or trade with jurisdictions subject
nd Terrorist Financing controls? (e.g. does the client transact with customers in countries No
ountries with weak AML and terrorist financing regimes?) No
N/A
N/A
N/A
Yes or No?
No
of our address for correspondence). No
f the firm’s business proportionate to the accountancy firm? Is the client’s business
Yes
Yes
N/A
N/A
N/A
Yes or No?
No
No
cing? (e.g. money services business, import/export, charities etc.) No
N/A
N/A
N/A
RISK Yes or No?
Yes
N/A
NOTES

ng process and part of its on-going monitoring. It should also be updated if there have been any significant changes.

Date:
TION, LEAVE BLANK OR HIDE THE ROW IF NOT NEEDED.

h the formulas further on in the document.

ompany).

ouse at the following address;

er-by-an-obliged-entity

h the formulas further on in the document.

Additional comments

Additional comments
 Additional comments

Additional comments

Additional comments

ave been any significant changes.

 CLIENT NAME: 0

CLIENT REFERENCE: 0

Know Your Client (KYC) - On-goin

Has the client’s registered name or trading name changed since the
client was on-boarded or last reviewed? PLEASE DO NOT DELETE ANY ROWS AS IT MAY CAUSE FO

Has the nature of the client’s business changed since the client was
on-boarded or last reviewed?

Has there been any change in the client’s company or VAT

registration numbers since the client was onboarded or last
reviewed?

Has the country the client is registered in and operating in changed

since the client was onboarded or last reviewed?

Has there been any change of

owners/partners/directors/Trustees/Settlors since the client was on-
boarded or last reviewed?

Has the client’s registered address changed since the client was
onboarded or last reviewed?

Has the client’s contact telephone number changed since the client
was onboarded or last reviewed?

Has the client’s email address changed since the client was
onboarded or last reviewed?

Has the client’s website changed since the client was onboarded or
last reviewed?

Has the client’s structure (if commercial entity i.e. a limited company
or partnership) changed since the client was on-boarded or last
reviewed?

Have there been any changes in share ownership since the client was
on-boarded or last reviewed?

Previous financial year turnover;

Projected turnover for next financial year;

Any other information or comments? If you need to add additional questions, ensu

Know Your Client (KYC) – On-going

 Know Your Client (KYC) – On-going

Are all beneficial owners/partners/directors photo ID’s and proof of

addresses up to date, with copies retained on file?

Has the photo ID and proof of address of all newly appointed owners,
partners, directors, Trustees and/or Settlors been obtained with
copies retained on file?

Has it been determined whether the beneficial owners has changed

since the client was onboarded or last reviewed? You must a

If there has been any change in the client’s structure, has the
corresponding documentation such a partnership agreement or
certificate of incorporation been obtained, and a copy retained on
file?

Has Companies House been recently consulted to confirm that

information provided by the client corresponds with information held The Fifth Money Laundering Dir
on the public register? https://www.gov.uk/guid

Has there been any change in the client’s key stakeholders since the i.
client was on-boarded or last reviewed?
Has an open source adverse media search been recently completed
online?
Has it been recently verified if the client has any significant overseas
interests or operations?

Has a reasonable risk-based approach been taken in relation to

sanctions screening?

<ADDITIONAL QUESTION1> If you need to add additional questions, ensu

CLIENT RISK ASSESSM

CLIENT RISK

Is the client a politically exposed person? (Politically exposed persons, PEPs, are individuals whose prominent position in public life ma
extends to immediate family members and known close associates).
Do you have full visibility and knowledge of the ultimate beneficial owners’ and/or all directors?
Is the client a high-net-worth individual? (e.g. assets of €1m/£1m or more)
Does the client or its beneficial owners have attributes known to be frequently used by money launderers or terrorist financiers? (e.g.
complex?)
Has evidence/documents proving income been provided? (e.g. invoices/bank statements)
Is the proof of identification and proof of address held on file valid and up-to-date?
Has the client been evasive or uncooperative? (e.g. appeared reluctant to provide ID)
Is the client a public administration, or a publicly owned enterprise?
Is the client/firm securities listed on a regulated market?
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
GEOGRAPHIC RISK
Is the client/firm based within close proximity of our firm? (e.g. within 10 miles).
Is the client based outside of Ireland?
Does the client have any association with a Sanctioned jurisdictions? (e.g. does the client transact with customers in sanctioned jurisdi
to
Doessanctions?)
the client have any association with any geographical areas that are considered to have weak AML and Terrorist Financing contro
listed on the 'FATF High-risk and other monitored jurisdictions' or the 'European Commission list of third countries with weak AML and
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
SERVICE RISK
Has, or will, the client be using our client money account?
Will we be providing trust or company services for the client? (This includes company formation and use of our address for correspond
Is the business relationship between you and the client logical and practicable? (For example, Is the size of the firm’s business proporti
within the accountancy firms areas of expertise?)
Is it understood why the client has come to use our services? (e.g. referred by an existing client)
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
INDUSTRY RISK
Would the client be typically considered a cash intensive business? (e.g. restaurants, retail outlets etc.)
Does the client deal with high value goods? (e.g. jewellers, car dealerships, properties etc.)
Does the client operate in an industry typically considered high-risk of money laundering or terrorist financing? (e.g. money services b
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
DELIVERY CHANNEL RISK
Have we ever met the client face-to-face?
<ADDITIONAL QUESTION1>
NOT
Use this section to summarise the client risks and any further comments

This client risk assessment is to be conducted at the on-boarding process and part of its on

Review of assessment of risk: High

Notes: (if there is any reason to override the initial assessment risk score it should
be stated here)

Conducted by:
Next date of review:
KYC) - On-going Monitoring Form - 2nd Review
PLACE COMMENTS/NOTES IN THIS SECTION.
Y ROWS AS IT MAY CAUSE FORMULAR ISSUES LATER IN THE DOCUMENT; EITHER AMEND THE QUESTION, LEAVE BLANK OR HIDE THE ROW IF NOT N

d additional questions, ensure you use the 'Insert Row' function. If not, you may cause an error with the formulas further on in the document.

C) – On-going Monitoring Checklist - 2nd Review

C) – On-going Monitoring Checklist - 2nd Review

If not, please give full details of action taken.

You must also consider beneficial owners that are not individuals (e.g. a limited company).

Fifth Money Laundering Directive obliges accountants to report any discrepancies to Companies House at the following address;
https://www.gov.uk/guidance/report-a-discrepancy-about-a-beneficial-owner-on-the-psc-register-by-an-obliged-entity

i.e. suppliers, overseas partners and other associated business partners.

d additional questions, ensure you use the 'Insert Row' function. If not, you may cause an error with the formulas further on in the document.

T RISK ASSESSMENT - 2nd Review

Yes or No?

ent position in public life may make them vulnerable to corruption. The definition
No
No
No
or terrorist financiers? (e.g. is the structure of the customer is unusual or excessively
No
No
No
No
No
No
N/A
N/A
N/A
K Yes or No?
No
 No
stomers in sanctioned jurisdictions or have operations or trade with jurisdictions subject
nd Terrorist Financing controls? (e.g. does the client transact with customers in countries No
ountries with weak AML and terrorist financing regimes?) No
N/A
N/A
N/A
Yes or No?
No
of our address for correspondence). No
f the firm’s business proportionate to the accountancy firm? Is the client’s business
No
No
N/A
N/A
N/A
Yes or No?
No
No
cing? (e.g. money services business, import/export, charities etc.) No
N/A
N/A
N/A
RISK Yes or No?
No
N/A
NOTES

rocess and part of its on-going monitoring. It should also be updated if there have been any significant changes.

Date:
TION, LEAVE BLANK OR HIDE THE ROW IF NOT NEEDED.

h the formulas further on in the document.

ompany).

ouse at the following address;

er-by-an-obliged-entity

h the formulas further on in the document.

Additional comments

Additional comments
 Additional comments

Additional comments

Additional comments

been any significant changes.

 CLIENT NAME: 0

CLIENT REFERENCE: 0

Know Your Client (KYC) - On-goin

Has the client’s registered name or trading name changed since the
client was on-boarded or last reviewed? PLEASE DO NOT DELETE ANY ROWS AS IT MAY CAUSE FO

Has the nature of the client’s business changed since the client was
on-boarded or last reviewed?

Has there been any change in the client’s company or VAT

registration numbers since the client was onboarded or last
reviewed?

Has the country the client is registered in and operating in changed

since the client was onboarded or last reviewed?

Has there been any change of

owners/partners/directors/Trustees/Settlors since the client was on-
boarded or last reviewed?

Has the client’s registered address changed since the client was
onboarded or last reviewed?

Has the client’s contact telephone number changed since the client
was onboarded or last reviewed?

Has the client’s email address changed since the client was
onboarded or last reviewed?

Has the client’s website changed since the client was onboarded or
last reviewed?

Has the client’s structure (if commercial entity i.e. a limited company
or partnership) changed since the client was on-boarded or last
reviewed?

Have there been any changes in share ownership since the client was
on-boarded or last reviewed?

Previous financial year turnover;

Projected turnover for next financial year;

Any other information or comments? If you need to add additional questions, ensu

Know Your Client (KYC) – On-going

 Know Your Client (KYC) – On-going

Are all beneficial owners/partners/directors photo ID’s and proof of

addresses up to date, with copies retained on file?

Has the photo ID and proof of address of all newly appointed owners,
partners, directors, Trustees and/or Settlors been obtained with
copies retained on file?

Has it been determined whether the beneficial owners has changed

since the client was onboarded or last reviewed? You must a

If there has been any change in the client’s structure, has the
corresponding documentation such a partnership agreement or
certificate of incorporation been obtained, and a copy retained on
file?

Has Companies House been recently consulted to confirm that

information provided by the client corresponds with information held The Fifth Money Laundering Dir
on the public register? https://www.gov.uk/guid

Has there been any change in the client’s key stakeholders since the i.
client was on-boarded or last reviewed?
Has an open source adverse media search been recently completed
online?
Has it been recently verified if the client has any significant overseas
interests or operations?

Has a reasonable risk-based approach been taken in relation to

sanctions screening?

<ADDITIONAL QUESTION1> If you need to add additional questions, ensu

CLIENT RISK ASSESS

CLIENT RISK

Is the client a politically exposed person? (Politically exposed persons, PEPs, are individuals whose prominent position in public life ma
extends to immediate family members and known close associates).
Do you have full visibility and knowledge of the ultimate beneficial owners’ and/or all directors?
Is the client a high-net-worth individual? (e.g. assets of €1m/£1m or more)
Does the client or its beneficial owners have attributes known to be frequently used by money launderers or terrorist financiers? (e.g.
complex?)
Has evidence/documents proving income been provided? (e.g. invoices/bank statements)
Is the proof of identification and proof of address held on file valid and up-to-date?
Has the client been evasive or uncooperative? (e.g. appeared reluctant to provide ID)
Is the client a public administration, or a publicly owned enterprise?
Is the client/firm securities listed on a regulated market?
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
GEOGRAPHIC RISK
Is the client/firm based within close proximity of our firm? (e.g. within 10 miles).
Is the client based outside of Ireland?
Does the client have any association with a Sanctioned jurisdictions? (e.g. does the client transact with customers in sanctioned jurisdi
to
Doessanctions?)
the client have any association with any geographical areas that are considered to have weak AML and Terrorist Financing contro
listed on the 'FATF High-risk and other monitored jurisdictions' or the 'European Commission list of third countries with weak AML and
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
SERVICE RISK
Has, or will, the client be using our client money account?
Will we be providing trust or company services for the client? (This includes company formation and use of our address for correspond
Is the business relationship between you and the client logical and practicable? (For example, Is the size of the firm’s business proporti
within the accountancy firms areas of expertise?)
Is it understood why the client has come to use our services? (e.g. referred by an existing client)
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
INDUSTRY RISK
Would the client be typically considered a cash intensive business? (e.g. restaurants, retail outlets etc.)
Does the client deal with high value goods? (e.g. jewellers, car dealerships, properties etc.)
Does the client operate in an industry typically considered high-risk of money laundering or terrorist financing? (e.g. money services b
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
DELIVERY CHANNEL RISK
Have we ever met the client face-to-face?
<ADDITIONAL QUESTION1>
NOT
Use this section to summarise the client risks and any further comments

This client risk assessment is to be conducted at the on-boarding process and part of its on

Review of assessment of risk: Low

Notes: (if there is any reason to override the initial assessment risk score it should
be stated here)

Conducted by:
Next date of review:
KYC) - On-going Monitoring Form - 3rd Review
PLACE COMMENTS/NOTES IN THIS SECTION.
Y ROWS AS IT MAY CAUSE FORMULAR ISSUES LATER IN THE DOCUMENT; EITHER AMEND THE QUESTION, LEAVE BLANK OR HIDE THE ROW IF NOT N

d additional questions, ensure you use the 'Insert Row' function. If not, you may cause an error with the formulas further on in the document.

YC) – On-going Monitoring Checklist - 3rd Review

YC) – On-going Monitoring Checklist - 3rd Review

If not, please give full details of action taken.

You must also consider beneficial owners that are not individuals (e.g. a limited company).

Fifth Money Laundering Directive obliges accountants to report any discrepancies to Companies House at the following address;
https://www.gov.uk/guidance/report-a-discrepancy-about-a-beneficial-owner-on-the-psc-register-by-an-obliged-entity

i.e. suppliers, overseas partners and other associated business partners.

d additional questions, ensure you use the 'Insert Row' function. If not, you may cause an error with the formulas further on in the document.

T RISK ASSESSMENT - 3rd Review

Yes or No?

ent position in public life may make them vulnerable to corruption. The definition
No
Yes
No
or terrorist financiers? (e.g. is the structure of the customer is unusual or excessively
No
Yes
Yes
No
Yes
Yes
N/A
N/A
N/A
K Yes or No?
Yes
 No
stomers in sanctioned jurisdictions or have operations or trade with jurisdictions subject
nd Terrorist Financing controls? (e.g. does the client transact with customers in countries No
ountries with weak AML and terrorist financing regimes?) No
N/A
N/A
N/A
Yes or No?
No
of our address for correspondence). No
f the firm’s business proportionate to the accountancy firm? Is the client’s business
Yes
Yes
N/A
N/A
N/A
Yes or No?
No
No
cing? (e.g. money services business, import/export, charities etc.) No
N/A
N/A
N/A
RISK Yes or No?
Yes
N/A
NOTES

rocess and part of its on-going monitoring. It should also be updated if there have been any significant changes.

Date:
TION, LEAVE BLANK OR HIDE THE ROW IF NOT NEEDED.

h the formulas further on in the document.

ompany).

ouse at the following address;

er-by-an-obliged-entity

h the formulas further on in the document.

Additional comments

Additional comments
 Additional comments

Additional comments

Additional comments

been any significant changes.

 CLIENT NAME: NOTE: The yellow highlighted c
questions, scoring and risk rati

CLIENT REFERENCE:
CLIENT RISK ASSESSM
CLIENT RISK

Is the client a politically exposed person? (Politically exposed persons, PEPs, are individuals whose prominent position in public life ma
extends to immediate family members and known close associates).
Do you have full visibility and knowledge of the ultimate beneficial owners’ and/or all directors?
Is the client a high-net-worth individual? (e.g. assets of €1m/£1m or more)
Does the client or its beneficial owners have attributes known to be frequently used by money launderers or terrorist financiers? (e.g.
complex?)
Has evidence/documents proving source of wealth and funds been provided?
Has the client provided proof of identification and proof of address?
Has the client been evasive or uncooperative? (e.g. appeared reluctant to provide ID)
Is the client a public administration, or a publicly owned enterprise?
Is the client/firm securities listed on a regulated market?
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
GEOGRAPHIC RISK
Is the client/firm based within close proximity of our firm? (e.g. within 10 miles).
Is the client based outside of Ireland?
Does the client have any association with a Sanctioned jurisdictions? (e.g. does the client transact with customers in sanctioned jurisdi
to sanctions?)

Does the client have any association with any geographical areas that are considered to have weak AML and Terrorist Financing contro
listed on the 'FATF High-risk and other monitored jurisdictions' or the 'European Commission list of third countries with weak AML and
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
SERVICE RISK
Will the client be using our client money account?
Will we be providing trust or company services for the client? (This includes company formation and use of our address for correspond
Is the business relationship between you and the client logical and practicable? (For example, Is the size of the firm’s business proporti
within the accountancy firms areas of expertise?)
Is it understood why the client has come to use our services? (e.g. referred by an existing client)
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
INDUSTRY RISK
Would the client be typically considered a cash intensive business? (e.g. restaurants, retail outlets etc.)
Does the client deal with high value goods? (e.g. jewellers, car dealerships, properties etc.)

Does the client operate in an industry typically considered high-risk of money laundering or terrorist financing? (e.g. money services b
<ADDITIONAL QUESTION1>
<ADDITIONAL QUESTION2>
<ADDITIONAL QUESTION3>
DELIVERY CHANNEL RISK
Have you met the client face to face?
<ADDITIONAL QUESTION1>
NOT
Use this section to summarise the client risks and any further comments

This client risk assessment is to be conducted at the on-boarding process and part of its on

Initial assessment of risk: Medium

Final assessment of risk:
Notes: (if there is any reason to override the initial assessment risk
score it should be stated here)

Conducted by: Date:

Agreed by: Date:

Next date of review? Date:

: The yellow highlighted cells provide information and help for you to manage and maintain the Client Risk Assessment tool. Please
stions, scoring and risk ratings are a guide only. You may adjust if you to adopt a more appropriate risk based approach for your firm
information can be found in the Help Scoring tab.

T RISK ASSESSMENT - Onboarding

Yes or No?

ent position in public life may make them vulnerable to corruption. The definition
No
Yes
No
or terrorist financiers? (e.g. is the structure of the customer is unusual or excessively
No
Yes
Yes
No
No
No
N/A
N/A
N/A
K Yes or No?
No
No
stomers in sanctioned jurisdictions or have operations or trade with jurisdictions subject
No

nd Terrorist Financing controls? (e.g. does the client transact with customers in countries
ountries with weak AML and terrorist financing regimes?) No
N/A
N/A
N/A
Yes or No?
No
of our address for correspondence). No
f the firm’s business proportionate to the accountancy firm? Is the client’s business
Yes
Yes
N/A
N/A
N/A
Yes or No?
No
No

cing? (e.g. money services business, import/export, charities etc.) No

N/A
N/A
N/A
RISK Yes or No?
Yes
 N/A
NOTES

rocess and part of its on-going monitoring. It should also be updated if there have been any significant changes.
ain the Client Risk Assessment tool. Please note the
propriate risk based approach for your firm. More
ab.

Additional comments

Additional comments

Additional comments

Additional comments

Additional comments
been any significant changes.
Is the client a politically exposed person? (Politically exposed persons, PEPs, are individuals
whose prominent position in public life may make them vulnerable to corruption. The
definition extends to immediate family members and known close associates).

Yes
100
No
0

NOTE: The yellow highlighted cells provide information and help for you to manage and
maintain the Client Risk Assessment tool. Please note the questions, scoring and risk
ratings are a guide only. You may adjust if you to adopt a more appropriate risk based
approach for your firm.
 CLIENT RISK

Is the client a high-net-

Do you have full visibility and knowledge
worth individual? (e.g.
of the ultimate beneficial owners’ and/or
assets of €1m/£1m or
all directors?
more)

0 0

Yes Yes
0 100
No No
100 0

PLEASE NOTE: This tab does not need to be updated when completing a clie
hidden these sheets. If you wish to amend, right click on the tabs below an
want to consider placing a password to protect the sheet from being altere
only.
 CLIENT RISK

Does the client or its beneficial owners have attributes

Has evidence/documents
known to be frequently used by money launderers or
proving source of wealth and
terrorist financiers? (e.g. is the structure of the customer is
funds been provided?
unusual or excessively complex?)

0 0

Yes Yes
100 0
No No
0 40

This tab does not need to be updated when completing a client risk assessment. Therefore we have
sheets. If you wish to amend, right click on the tabs below and unhide the relevant sheet. You may
der placing a password to protect the sheet from being altered. This sheet is for illustration purposes
only.
 Has the client Has the client been evasive Is the client a public
Is the client/firm
provided proof of or uncooperative? (e.g. administration, or a
securities listed on a
identification and appeared reluctant to publicly owned
regulated market?
proof of address? provide ID) enterprise?

0 0 0 0

Yes Yes Yes Yes

100 100 -1 -1
No No No No
0 0 0 0
 Is the client/firm based Is the client
<ADDITIONAL <ADDITIONAL <ADDITIONAL within close proximity based
QUESTION1> QUESTION2> QUESTION3> of our firm? (e.g. within outside of
10 miles). Ireland?

0 0 0 40 0

Yes Yes Yes Yes Yes

100 100 100 0 40
No No No No No
0 0 0 40 0
N/A N/A N/A
0 0 0
 GEOGRAPHIC RISK

Does the client have any association with a Sanctioned

jurisdictions? (e.g. does the client transact with customers in
sanctioned jurisdictions or have operations or trade with
jurisdictions subject to sanctions?)

Yes
100
No
0
 GEOGRAPHIC RISK

Does the client have any association with any geographical areas that are considered to have weak
AML and Terrorist Financing controls? (e.g. does the client transact with customers in countries listed
on the 'FATF High-risk and other monitored jurisdictions' or the 'European Commission list of third
countries with weak AML and terrorist financing regimes?)

Yes
100
No
0
 Will the client
<ADDITIONAL <ADDITIONAL <ADDITIONAL be using our
QUESTION1> QUESTION2> QUESTION3> client money
account?

0 0 0 0

Yes Yes Yes Yes

100 100 100 40
No No No No
0 0 0 0
N/A N/A N/A
0 0 0
 SERVICE RISK

Will we be providing trust or company

services for the client? (This includes
company formation and use of our
address for correspondence).

Yes
40
No
0
 SERVICE RISK

Is the business relationship between you and the client logical and Is it understood why the
practicable? (For example, Is the size of the firm’s business client has come to use our
proportionate to the accountancy firm? Is the client’s business within services? (e.g. referred by an
the accountancy firms areas of expertise?) existing client)

0 0

Yes Yes
0 0
No No
100 100
 Would the client be typically
<ADDITIONAL <ADDITIONAL <ADDITIONAL considered a cash intensive
QUESTION1> QUESTION2> QUESTION3> business? (e.g. restaurants,
retail outlets etc.)

0 0 0 0

Yes Yes Yes Yes

100 100 100 100
No No No No
0 0 0 0
N/A N/A N/A
0 0 0
 INDUSTRY RISK

Does the client deal with Does the client operate in an industry typically
high value goods? (e.g. considered high-risk of money laundering or <ADDITIONAL
jewellers, car dealerships, terrorist financing? (e.g. money services business, QUESTION1>
properties etc.) import/export, charities etc.)

0 0 0

Yes Yes Yes

100 100 100
No No No
0 0 0
N/A
0
 DELIVERY CHANNEL RISK

TOTAL RISK
<ADDITIONAL <ADDITIONAL Have you met the <ADDITIONAL SCORE RATING
QUESTION2> QUESTION3> client face to face? QUESTION1>

0 0 0 0 40 Medium

Yes Yes Yes Yes

100 100 0 100
No No No No
0 0 100 0
N/A N/A N/A
0 0 0
Drop Down
Options
Yes
No
N/A