The firms work against money laundering and counter terrorism shall be risk based and as a first step the firms shall conduct a general risk assessment. Among other things, the firm shall take into account:
the type of products and services offered
what kind of customers the firm has (for instance mostly companies or natural persons)
the geographic risk, both local, in Sweden and international. The firm has to take into account if the firm provides foreign payments and so on.
the firm’s distribution channels, over the internet or over counter.
The firm shall also take into account analyses and experiences from monitoring and reporting to FIU. A good source of information for conducting the general risk assessment is the Risk Factor Guidelines from EBA, Risk Factor Guidelines (EBA) .
The scope of the risk assessment should be determined by the size and nature of the business.
The risk assessment must be documented and evaluated and updated regularly, at least once a year. When the firm offers new products and services, there is also a need for an update.
The national risk assessment, developed by the Swedish “Samordningsfunktionen”, can also give some guidance to the risks the firm has to consider, National Risk Assessment of Money Laundering and Terrorist Financing in Sweden 2020/2021