I am a member of the ICB, I am startimg work for a new client next week, before I start work do I need to complete the a "Client Risk Assessment" and a "Client Due Diligence Record"?
The client risk assessment is basically an opinion based on circumstance and can change each year. In the first year, the best assessment will be medium because will not know the client that well but can assess that if the transactions are mainly accounts and go through a bank and the paperwork appears to all be in order etc, then I would assess medium in the first year (probaly low in the second, depending what you felt). If the client dealt in cash, and had poor records then he would probably be a high risk. You also need to consider if the client falls in to the politically expose person category as well.
Due diligence just means you are taking the necessary checks to ensure the client is who they say they are, with evidence to show you have done so (copies of driving licence etc).
Neither have to be done immediately but as soon as practical. The only thing the client will be aware of is when you ask for the ID evidence and that's what you need on your records as soon as possible. You may not be able to make an immediate assessment.
There is nothing in the manual (as far as I can see) that advises anything. However, it is your own opinion/ judgement based on some facts. It does not imply that the clients will commit any ML offence, it is just that the opportunity is greater (more exposed to temptation even!), so you should be more vigilant, with this category of client. Similarly, a politically exposed person is a higher risk because they are open to all sorts of pressures (blackmail, bribery etc) to launder money.
