Customer due diligence risk scoring checklist
CDD risk scoring under AML/CTF assigns a risk rating to each client that drives the level of due diligence applied. This checklist is for law firm AML officers building a risk scoring framework.
This is a 12-step customer due diligence risk scoring checklist. It covers client, service, geography, channel, and transaction factors.
The checklist
Assess client type risk
Assess risk based on whether the client is individual, company, trust, PEP, or high-risk structure.
Assess business activity
Assess risk of the client's industry — cash-intensive, gambling, crypto, or high-risk sectors.
Assess geography
Assess geographic risk — country of residence, registration, and source of funds.
Check sanctions/high-risk countries
Check whether any party is in a FATF high-risk or monitored jurisdiction.
Assess service risk
Assess the risk of the designated service — real estate, trust formation, cash handling.
Assess delivery channel
Assess delivery channel risk — face-to-face vs remote onboarding.
Assess transaction complexity
Assess complexity, value, and opacity of the transaction.
Apply PEP uplift
Apply a risk uplift if any party is a politically exposed person.
Calculate composite score
Calculate a composite risk score using weighted factors.
Classify risk band
Classify as low, medium, or high risk with a defined CDD treatment.
Document scoring
Document the scoring rationale in the client file.
Periodic reassessment
Reassess the score at defined intervals or on material change.
When this checklist applies
Use at onboarding for every client and at periodic review.
Common pitfalls
- Not weighting geography high enough
- Missing PEP uplift
- Composite score not reflecting transaction risk
- Risk scoring rationale not documented
- Periodic reassessment not scheduled
Run this checklist on a real matter
Quillio can calculate CDD risk scores using client data and automate periodic review. See /practice-areas/firm-management or start a free trial.
General guidance for CDD risk scoring. Align with firm AML/CTF program and AUSTRAC guidance.
Use this checklist on your matter.
Quillio can run this checklist on a specific NSW conveyancing matter — confirm each item, calculate adjustments, and generate the supporting documents. The free trial requires no credit card.
Start your free trial