Deterministic heuristic risk scoring using a four-factor weighted model (Geographic 30%, Customer 35%, Product 25%, Channel 10%) aligned with Basel III, EBA Guidelines, FATF standards, and FinCEN guidance. Bands: LOW (0-20), MEDIUM (21-60), HIGH (61-80), CRITICAL (81-100).
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Deterministic heuristic risk scoring using a four-factor weighted model aligned with Basel III, EBA Guidelines, FATF standards, and FinCEN guidance.
Risk assessment is performed during onboarding and refresh to classify customers into risk bands that determine the level of due diligence required and ongoing monitoring frequency.
| Indicator | Score Range |
|---|---|
| UK/EU/US/developed economy | 5-15 |
| Mid-tier economies | 20-40 |
| FATF grey-list jurisdictions | 50-70 |
| High-risk/sanctioned jurisdictions | 80-100 |
| Multiple jurisdictions with offshore | +10-20 |
Assessed for: Customer residence, nationality, transaction destinations, wealth origin, business operations.
| Indicator | Score Range |
|---|---|
| Salaried employee, standard profile | 5-15 |
| Self-employed, professional | 20-35 |
| Business owner, HNWI | 40-60 |
| PEP (any tier) | 60-80 |
| Complex structures, unclear ownership | 70-90 |
| Adverse media findings | +20-40 |
Assessed for: Occupation, PEP status, source of wealth clarity, business complexity, directorships, adverse media.
| Indicator | Score Range |
|---|---|
| Personal current/savings account | 5-15 |
| Investment/wealth management | 20-40 |
| Trade finance, correspondent banking | 50-70 |
| Virtual assets, high-value transactions | 60-80 |
| Complex structured products | 70-90 |
Assessed for: Account type, expected activity, transaction volume, product complexity.
| Indicator | Score Range |
|---|---|
| Face-to-face, standard onboarding | 5-10 |
| Remote/digital onboarding with verification | 15-25 |
| Intermediary-introduced | 30-50 |
| Anonymous/pseudonymous channels | 70-90 |
Assessed for: Onboarding method, documentation quality, intermediary involvement.
Total Score = (Geographic x 0.30) + (Customer x 0.35) + (Product x 0.25) + (Channel x 0.10)
| Band | Score | Due Diligence | Approval Level | Monitoring |
|---|---|---|---|---|
| LOW | 0-20 | Standard CDD | Analyst | 3-5 year review |
| MEDIUM | 21-60 | Enhanced monitoring | Senior Analyst | 1-2 year review |
| HIGH | 61-80 | Full EDD | Manager + MLRO | 6-12 month review |
| CRITICAL | 81-100 | Immediate escalation | Senior Management | Quarterly or reject |
The risk score is deterministic:
While the score is calculated automatically, the analyst must:
The human always has final say on risk classification.
Automatic escalation regardless of score:
Version: 1.0.0 Author: Vyayasan