SRA Updates its AML/CTF Sectoral Risk Assessment

The major changes from the previous Sectoral Risk Assessment dated July 2023 are as follows:

• Coverage of new risks: vendor fraud, pooled client funds, third-party managed accounts, and irregular methods of transferring funds;
• The classification of sanctions under its own risk heading;
• Amended references to Covid-19, retaining risks which have become part of usual business and removing those which are no longer relevant;
• Coverage of the risk of modern slavery in relation to cash-based industries;
• The inclusion of further references to AI and cybercrime; and
• An updated position regarding domestic PEPs.