The risk analysis/assessment entails the assessment of each inherent risk factor for the likelihood of occurrence, and impact, were to occur.
Services offered by Easyterms Ltd. Include:
Money Lending
Easyterms Ltd. facilitates loans to finance the purchase of used cars for sale by one of its associated companies. While Easyterms Ltd. is a regulated financial entity and would be classified as low risk for regulated financial entities, the purpose for which the loan is being made and the type of business (Easy Car Sales) is categorized as medium risk. The probability of ML is low but it is likely to occur but acceptable. Almost all of Easyterms Ltd. clients/customers work for government institutions and payment is made by salary deductions. All clients/customers are subject to full CDD.
PROBABILITY OF USE FOR ML | LIKELY IMPACT IF USED | OVERALL RISK |
Low | Medium | Medium |
A major portion of the company customers are referred from similarly regulated institutions, who have already conducted due diligence on the client. In addition, Easyterms Ltd. conducts its own due diligence, which may entail incorporating parts of the referrer’s CDD.
The Company’s policies and procedures are considered adequate for ensuring that this delivery channel has low risk of being used for money laundering; therefore, a low probability of this occurrence and little impact.
PROBABILITY OF USE FOR ML | LIKELY IMPACT IF USED | OVERALL RISK |
Low | Low | Low |
The Majority of the Company’s clients/customers are employees of some form of government institution. The fact that full CDD is conducted on each employee and payment is made via salary deductions makes the probability and likelihood of ML is very low.
The Company’s policies and procedures are considered adequate for ensuring that this delivery channel has low risk of being used for money laundering; therefore, a low probability of this occurrence and little impact.
PROBABILITY OF USE FOR ML | LIKELY IMPACT IF USED | OVERALL RISK |
Low | Low | Low |
Very few of the Company’s clients/customer are walk-in or private individuals. If the Company do accept these types of customers, Full CDD is conducted to ensure that this delivery channel has low risk of being used for money laundering. The Company will not receive cash from or for a client, custody client cash or pay cash to or for a client. All receipts must come from another financial institution (via wire, cheque, draft or salary deduction) and returned to client (or potential client) in the same manner. Where a potential relationship is not established and funds are returned, they will only be returned to the original payer.
The Company’s policies and procedures are considered adequate for ensuring that this delivery channel has low risk of being used for money laundering; therefore, a low probability of this occurrence and very little impact.
PROBABILITY OF USE FOR ML | LIKELY IMPACT IF USED | OVERALL RISK |
Low | Low | Low |
Client based includes jurisdiction within and outside of the Bahamas
Place of birth of facility holder
Residence of the facility holder
Place of business activity
Reference to risk level per jurisdiction is applied by reference to FATF. That information will be updated from time to time, but at least annually, and includes all jurisdictions to which Easyterms Ltd. can be exposed.
Example list
It is the Company policy not to engage in relationships with high risk countries, however, if this were to occur, that risk would be assessed and increase the possibility of a high risk rating and therefore enhanced due diligence would be conducted.
No business is conducted with any sanctioned country, as stipulated by notification from regulators. Target clients and customers are from the Bahamas and countries with AML regulations on par with the Bahamas.
Easyterms Ltd. also take into consideration the place of birth, residence and principal location of the business or profession of the clients/customers which facilitates the assessment of risk brought by exposure to that jurisdiction.
PROBABILITY OF USE FOR ML | LIKELY IMPACT IF USED | OVERALL RISK |
Low | Low | Low |
Occupation is covered via business activities; (see Appendix 2) Business/professional activity is selected from the list, where rating is assigned based on the risk category.
Easyterms Ltd. has clients that are individuals and companies. The risk matrix rates for companies as low risk for AML as CDD policies and procedures mitigate the risk of engaging with a client, who brings ML risk to the Company.
In addition, the majority of Easyterms Ltd. clients/customers are via a similarly regulated Financial Institution, which conducts its own due diligence.
PROBABILITY OF USE FOR ML | LIKELY IMPACT IF USED | OVERALL RISK |
Low | Low | Low |
Easyterms Ltd. transactions are limited to structure monthly loan payments. Anything outside of 12 monthly installments will be flagged and monitored.
PROBABILITY OF USE FOR ML | LIKELY IMPACT IF USED | OVERALL RISK |
Low | Low | Low |
Easyterms Ltd. does not partake in any cash transaction with or for clients. The Company will not receive cash from or for a client, custody client cash or pay cash to or for a client. All receipts must come from another financial institution (via wire, cheque, draft or salary deduction) and returned to client (or potential client) in the same manner. Where a potential relationship is not established and funds are returned, they will only be returned to the original payer.
PROBABILITY OF USE FOR ML | LIKELY IMPACT IF USED | OVERALL RISK |
Low | Low | Low |
Pursuant to legislation, PEP’s are automatically rated as High Risk, and therefore subject to enhanced due diligence.