The auditor finds that thecustomer risk assessment (CRA) is completed at initial onboarding and is...

Dynamic Nature of Customer Risk Assessment (CRA):

A comprehensive CRA should incorporate jurisdictional risks, as customer location changes could introduce new risks, such as exposure to high-risk or non-compliant jurisdictions​​.

FATF Recommendations on Risk-Based Approach:

Periodic updates to the CRA, including changes in customer location, align with FATF’s risk-based approach and Recommendation 10​​.

Audit Observation Implications:

Omission of jurisdictional assessments could result in undetected risks, undermining the integrity of the AML program.