The SRA has published an update to its sectoral risk assessment. MLROs should read this document carefully and update their firms’ practice-wide risk assessments as necessary.
The major changes from the previous Sectoral Risk Assessment (dated 5 March 2024) are as follows:
- Updated references to, and summary of, the National Risk Assessment.
- Added new emerging risks:
- capital flight from high-risk countries
- client account issues
- poor CDD scrutiny
- changing firm business models
- Moved the following risks from emerging to new locations, reflecting that they are now part of the risk landscape:
- vendor fraud
- proliferation financing
- supply chain risk.
- Added further updates and context to the Sanctions section, including new designations and penalties imposed.
