risk-assessment

name	risk-assessment
description	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).
user-invocable	true
category	compliance
estimated-duration	10 minutes

Risk Assessment Skill - v1.0.0

Deterministic heuristic risk scoring using a four-factor weighted model aligned with Basel III, EBA Guidelines, FATF standards, and FinCEN guidance.

Overview

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.

Four-Factor Risk Model

Factor 1: Geographic Risk (30% Weight)

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.

Factor 2: Customer Risk (35% Weight)

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.

Factor 3: Product Risk (25% Weight)

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.

Factor 4: Channel Risk (10% Weight)

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.

Risk Score Calculation

Total Score = (Geographic x 0.30) + (Customer x 0.35) + (Product x 0.25) + (Channel x 0.10)

Risk Bands and Required Actions

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

Determinism Guarantee

The risk score is deterministic:

• Same inputs always produce the same score
• No subjective judgment in calculation
• Mathematical formula applied consistently
• Ensures fairness and reproducibility
• Auditable by regulators

HITL Checkpoint

While the score is calculated automatically, the analyst must:

1. Review the calculated score
2. Confirm the input factors are accurate
3. Sign off on the risk classification
4. Approve or challenge the recommended action

The human always has final say on risk classification.

Escalation Triggers

Automatic escalation regardless of score:

• PEP status identified
• Sanctions match (true or uncertain)
• Material misrepresentation detected
• Source of wealth/funds unexplained
• Multiple high-risk indicators combined

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Version: 1.0.0 Author: Vyayasan