Annex 1 GwG – Factors indicating a potentially lower risk

The following is a non-exhaustive list of factors and types of evidence of potentially lower risk under section 14:

Customer risk factors:
a) public companies listed on a stock exchange and subject to disclosure requirements (either by stock exchange rules or through law or enforceable means), which impose requirements to ensure adequate transparency of beneficial ownership,
b) public administrations or companies,
c) customers that are resident in geographical areas of lower risk as set out in no. 3.
Product, service, transaction or delivery channel risk factors:
a) life insurance policies for which the premium is low,
b) insurance policies for pension schemes if there is no early surrender option and the policy cannot be used as collateral,
c) a pension, superannuation or similar scheme that provides retirement benefits to employees, where contributions are made by way of deduction from wages, and the scheme rules do not permit the assignment of a member’s interest under the scheme,
d) financial products or services that provide appropriately defined and limited services to certain types of customers, so as to increase access for financial inclusion purposes,
e) products where the risk of money laundering and terrorist financing are managed by other factors such as purse limits or transparency of ownership (e.g. certain types of electronic money).
Geographical risk factors – registration, establishment, residence in:
a) member states,
b) third countries having effective systems for the prevention, detection and combating of money laundering and terrorist financing,
c) third countries identified by credible sources as having a low level of corruption or other criminal activity,
d) third countries which, on the basis of credible sources such as mutual evaluations, detailed assessment reports or published follow-up reports, have requirements to prevent, detect and combat money laundering and terrorist financing consistent with the revised FATF