Risk-Based Approach (RBA)
The RBA is the reason two investors in the same fund can go through different levels of checks. It does not remove the core obligations a firm must meet. It decides how far each control goes, and it makes the firm responsible for showing why. FATF calls it "an effective way to combat money laundering and terrorist financing" and says it allows firms to "allocate their own resources in the most effective way" (Interpretive Note to Recommendation 1, para 1).
The two levels of risk assessment
In practice the RBA works at two levels. The Hong Kong SFC Guideline names them clearly (para 2.1):
- Institutional (business-wide) risk assessment. How, and to what extent, the firm as a whole is exposed to money laundering and terrorist financing (para 2.2), given its customers, markets, products and channels. It shapes the firm's policies, procedures and controls.
- Customer risk assessment. The risk of a particular customer or proposed relationship, which sets the degree, frequency or extent of CDD and ongoing monitoring. The SFC says firms may do this by assigning a risk rating to each customer (para 2.16).
For a fund manager, the first is the enterprise-wide assessment reviewed by the board or senior management. The second is the investor risk rating decided at onboarding and revisited at each review.
The four risk factors
FATF lists the same factors that national rules repeat: customers; countries or geographic areas; products, services and transactions; and delivery channels (Interpretive Note to Recommendation 1, para 12). FATF also says firms "should consider all the relevant risk factors before determining what is the level of overall risk" (para 16).
| Risk factor | What it covers | Examples for a fund manager (our illustrations) |
|---|---|---|
| Customer | Who the customer and its beneficial owners are, and how they are structured | A listed pension fund versus a newly formed holding company owned through a trust; an investor who is a politically exposed person |
| Country or geographic area | Where the customer is from or operates, and where the firm itself operates | Investors resident in, or paying from, higher-risk countries; beneficial owners in countries with weak beneficial ownership transparency |
| Products, services and transactions | How the product can be used to move or hide money | Open-ended funds with frequent dealing versus closed-ended funds with capital calls; transfers of interests; redemptions to third parties |
| Delivery channels | How the relationship is established and serviced | Non-face-to-face onboarding; subscriptions through nominees, platforms or distributors; reliance on third parties for CDD |
How regulators write it into the rules
The wording varies, but the structure is the same: assess, document, keep up to date, control, and scale the controls to the risk.
| Source | What it requires |
|---|---|
| FATF (Recommendation 1 and its Interpretive Note, paras 12 to 16) | Financial institutions should identify and assess ML/TF risks for customers, countries or geographic areas, products, services, transactions and delivery channels; document the assessment and keep it up to date; have senior-management-approved controls; apply enhanced measures where risk is higher; and may be allowed to apply simplified measures where risk is lower |
| Singapore (MAS Notice SFA04-N02, paras 4.1 to 4.3) | Capital markets intermediaries must identify, assess and understand their ML/TF risks in relation to customers, the countries their customers are from or in, the countries where they operate, and products, services, transactions and delivery channels; document and update the assessment; adopt senior-management-approved controls; and perform enhanced measures where higher risks are identified |
| Hong Kong (SFC AML/CFT Guideline, Chapter 2) | An institutional risk assessment, documented (para 2.10), approved by senior management (para 2.11) and reviewed at least every two years, or more often after trigger events with a material impact (para 2.9), plus a customer risk assessment that sets the degree, frequency or extent of CDD and ongoing monitoring (para 2.1) |
| United Kingdom (Money Laundering Regulations 2017, regs 18 and 19) | Appropriate steps, taking account of the size and nature of the business, to identify and assess risks, including those relating to customers, countries or geographic areas, products or services, transactions and delivery channels, with an up-to-date written record (reg 18); and proportionate policies, controls and procedures approved by senior management (reg 19) |
| Cayman Islands (Anti-Money Laundering Regulations (2025 Revision), reg 8) | Steps appropriate to the nature and size of the business to identify, assess and understand ML, TF and PF risks; a documented, up-to-date assessment; senior-management-approved controls; and enhanced CDD where higher ML or TF risks are identified |
| Luxembourg (CSSF Regulation 12-02, Article 5) | Every customer is categorised by risk level, assessed before the customer is accepted and updated during the relationship; the risk assessment cannot be used to avoid enhanced due diligence where the law requires it |
What the risk-based approach does not allow
- Skipping the core CDD steps. FATF Recommendation 10 says firms should be required to apply each CDD measure, with the extent set using the RBA.
- Simplified measures where there is suspicion. FATF says simplified measures "should not be permitted whenever there is a suspicion of money laundering or terrorist financing" (Interpretive Note to Recommendation 1, para 2).
- Risk-based sanctions compliance. FATF says the targeted financial sanctions obligations in Recommendation 7 "are not risk-based". Risk-based measures for proliferation financing are there to support full compliance with those obligations, not to replace it (para 3).
- Avoiding mandatory enhanced due diligence. Where the law sets enhanced due diligence for a situation, a lower internal rating does not remove it. CSSF Regulation 12-02 says this expressly (Article 5(3)).
- Undocumented judgments. The SFC expects firms to keep records showing how they assessed a customer's risk and why the extent of CDD and monitoring fits it (para 2.18).
Applying the RBA in a fund: an illustration
A manager runs a closed-ended private equity fund. Its business-wide assessment identifies higher risk from investors who subscribe through holding companies with layered ownership, and from investors linked to higher-risk countries. Its customer risk methodology therefore rates a regulated pension fund investing in its own name as lower risk, so the manager applies the checks its rules require, which may be simplified where those rules allow. A new investment holding company owned through a discretionary trust, with a beneficial owner who is a foreign politically exposed person, is rated high risk and gets enhanced due diligence: senior management approval, source of wealth and source of funds checks, and more frequent reviews. The Cayman Islands Monetary Authority's guidance for mutual funds says investors rated low "may be subject to SDD procedures" (a low rating is valid only if it is consistent with the national risk assessment or the supervisor's findings), those rated medium "may be subject to normal CDD procedures", and those rated high "must be subject to EDD procedures" (Guidance Notes, Part VI, Section 1, mutual funds, section D, para 5).
Keeping the assessment current
A risk assessment is not a one-off document. MAS and FATF require it to be kept up to date. The SFC sets a review at least every two years, or sooner after trigger events such as new customer segments, new products or a significant control breach (para 2.9). At customer level, the UK regulations require customer due diligence on existing customers at appropriate times on a risk-based approach and when circumstances relevant to the customer's risk assessment change, taking into account, for example, any indication that the identity of the customer or its beneficial owner has changed (reg 27(8) and (9)). CSSF Regulation 12-02 says the customer's risk level must be assessed before acceptance and adapted to any significant change during the relationship (Article 5(4)).
Key points
- Set out in FATF Recommendation 1 and its Interpretive Note; national rules in Singapore, Hong Kong, the UK, the Cayman Islands and Luxembourg follow the same structure
- Works at two levels: a business-wide risk assessment and a customer risk assessment
- Four risk factors: customers; countries or geographic areas; products, services and transactions; delivery channels
- Higher risk requires enhanced measures; lower risk may allow simplified measures where the rules permit, but never when there is suspicion
- Targeted financial sanctions obligations are not risk-based; the assessment must be documented and kept up to date, and the controls approved by senior management
How One Constellation helps
One Constellation gives fund managers, administrators and transfer agents a SaaS AML/KYC platform with customer risk assessment, identity verification, KYB and beneficial-owner records, sanctions, PEP and adverse-media screening, transaction monitoring, and case management with STR/SAR workflows. Your risk methodology and decisions stay with your compliance team.
Explore Customer Risk AssessmentFrequently asked
Sources
- FATF: The FATF Recommendations (updated June 2026), Recommendation 1 and its Interpretive Note, and Recommendation 10
- MAS: Notice SFA04-N02 on prevention of money laundering and countering the financing of terrorism, capital markets intermediaries (30 June 2025, PDF), paragraph 4
- SFC: Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations and SFC-licensed Virtual Asset Service Providers), June 2023 (PDF), Chapter 2
- legislation.gov.uk: The Money Laundering Regulations 2017, regulation 18
- legislation.gov.uk: The Money Laundering Regulations 2017, regulation 19
- legislation.gov.uk: The Money Laundering Regulations 2017, regulation 27
- CIMA: Anti-Money Laundering Regulations (2025 Revision) (PDF), regulation 8
- CIMA: Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the Cayman Islands (February 2024, PDF), Part VI, Section 1 (mutual funds)
- CSSF: CSSF Regulation No 12-02 of 14 December 2012, as amended by CSSF Regulation No 20-05 (PDF), Article 5
This entry is general information, not legal advice. Check the current text with the regulator before relying on it. Sources read on 9 November 2026.
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