Risk Assessment LawWare Ltd support@lawware.co.uk lawware.co.uk
Contents The purpose of this manual is to take you through the Risk Assessment module. This is an optional module and is used to calculate the risk at client and case file level. This guide will cover the Risk Assessment module in more detail. Contents... 1 Client Risk Assessment Information... 2 Case File Risk Assessment Information... 4 The Risk Assessment Activity... 6 Viewing the CDD Risk Assessment Screen at a Later Date... 9 Viewing High Risk Assessments... 10 To Set a Notification... 11 Notifications for Partners and Fee Earners... 13 Notifications for the MLRO... 13 Notes... 14 Page 1
Client Risk Assessment Information The Risk assessment module allows you to input responses to risk based questions and determines if the MLRO (Money Laundering Reporting Officer) is required to authorise the client before concluding that the firm may continue to act for them. The Risk Assessment Module works with the Productivity Centre to display which clients have been referred and an audit trail will record which MLRO authorises the client. Completing the Risk Assessment To complete the Risk Assessment there are 2 stages that appear in the Money Laundering screen (client level). Stage (1) is covered in the Money Laundering manual. Stage (2) Risk Assessment at client level will appear as below: The first has 2 questions which should be selected if relevant at client level. Users will need the MLRO to approve a client if they select either a Politically Exposed Person (PEP) or is the are showing ID that has been provided by a 3 rd Party. The MLRO is notified of this referral through the KPI - Client High Risk Assessment (CDD) in the Productivity Centre notifications. Refer to the section Viewing High Risk Assessments for further information. Selecting any of the two top options will immediately flag a referral to the MLRO. The client will be listed in the relevant KPI for the MLRO to review and approve. Only the MLRO can Page 2
The third option Do not perform checks means that the system will not prompt you to complete a risk assessment at client level each time a case file is added for the client. A client that has not had the ID checks completed will show the red no entry symbol screen until it has been completed or authorised by the MLRO in the main client Page 3
Case File Risk Assessment Information When creating a new Case File, users will be prompted to complete the Money Laundering Regulations Customer Due Diligence (CDD) questionnaire. This is to allow for work type specific questions to display on the risk assessment form. If you do not have this information you can refer back to this screen at a later date. See Viewing the CDD Risk Assessment at a later date. The CDD Risk Assessment Questionnaire: Work Type specific questions indicaton Clicking the Add Notes button displays the Narrative box for users to add additional information. When prompted the above box will appear allowing you to fill in the questionnaire. To complete answer each question and select either Low, Medium or High risk. You can also add notes if required by clicking on the Add Notes button. Note: These questions can be changed, please refer to the Lawware administrator Page 4
Select each question and note that where the risk score is greater than 50% the banner at the top of the screen will change from yellow to red to inform you that this client should be referred to the MLRO. Note: The percentage is a guide figure and can be changed by the Lawware administrator. When you have finished the questionnaire Click OK to save the Risk Assessment. This Will generate the Risk Assessment Activity sheet which you can save and/or print off. See The Risk Assessment Activity. Note: The warning below will be displayed if The risk assessment is incomplete Has been referred to the MLRO Has been rejected by the MLRO If both the client money laundering ID and the risk assessment have not been completed you will see this message when you double click the case file. Page 5
The Risk Assessment Activity When users click OK on the Risk Assessment screen after updating at case file level it will create a PDF document with an associated activity as shown below. This will record which user has completed the risk assessment, what the answers to the questions have been at that time, and any MLRO Approval/Rejection details. This PDF document and associated activity cannot be deleted from within the case file. The reason for this is to record all changes made to the risk assessment without the record becoming compromised. The results of the risk assessment can be located within the activities view within the case file. Page 6
The CDD risk assessment activity screen will take the standard activity screen format as per the screen shot below. Activity type cannot be amended The risk assessment activity will have a default Description and File Note that displays one of the following narrative: - Risk Assessment Referred o All questions are answered but the score exceeds the threshold. o There are high individual risk items selected. o The MLRO hasn t yet approved or rejected the risk assessment. Risk Assessment Rejected The MLRO has rejected the risk assessment. Risk Assessment Satisfactory All questions are answered and the overall score is lower than the threshold. Risk Assessment Approved The MLRO has approved the risk assessment. Note: Users can customise the main Case File screen to display the additional columns MLRO Name and MLRO Approval Date. This will display case files that have been approved allowing for main screen reporting if desired. Page 7
Deleting the Risk Assessment Activity Attempting to delete this activity type will result in the following message being displayed to users. The risk assessment activity can t be deleted. Whenever a user makes an amendment to any of the risk assessment answers a new activity and PDF will be created. This allows for a clear historic trail of the risk assessment process which is accessible from within the case file. Demonstrating that the case file had been adequately risk assessed throughout each stage of the case Page 8
Viewing the CDD Risk Assessment Screen at a Later Date If you do not have the risk assessment details available at the time of creating the case file you can review the questionnaire at a later date. Within in the CDD screen Click OK to continue to enter details later. The following prompt will appear. Click No to close the risk assessment screen or if you wish to fill in the details select Yes to continue with the risk assessment. Note: A case file that requires risk assessment is shown in the case file list with a Red No entry symbol To complete the CDD Risk Assessment later select Options within the case file and scroll down to Money Laundering Risk Assessment (CDD) as shown below. This will re-open the risk assessment questionnaire for completion and previous steps should be followed. Page 9
Viewing High Risk Assessments If the risk assessment information has been added and the system highlights that you should refer the client or case file to MLRO, the MLRO should authorise the client or case file before the firm continues to act for the client. If the client has been marked as politically exposed or showing 3 rd Party id, they will be referred to the MLRO and show as High Risk. If a Case Files has a question marked as High risk or the total of answers equals more than the % set it will be referred to the MLRO and show as High Risk. To View clients with a high risk assessment open the Productivity Centre. From the Productivity Centre, Click on View and select Notifications. Click on Configure Notifications highlighted in blue on the bottom right hand corner. A list will be presented as shown below: Under the Clients and Files heading select the appropriate notifications: - Note: If the Productivity Centre is not on screen, it can be displayed by clicking the icon at the bottom left corner. Page 10
To Set a Notification When you select a Notification to view you will be presented with options dependant on your permission levels Within the settings, you can set parameters as to when you will receive warnings In this example I have set the:- Case Files awaiting MLRO authorisation to alert me when there are 2 case files needing my attention and to display a pop up message when I log on to Lawware, see example of popup message below. When configuring the notification, make sure you select Items for the entire practice. If you are the MLRO so that you see all the current active case files. If you are the Fee Earner or Partner of a Case File select Items that belong to (Me only) so that you can see the status of your Case Files only. Once the notification has been set in the Productivity Centre, the summary will display in bold if there is data to report Page 11
Double click on any bold notification to display a report on the left-hand screen, as shown below: Right Click on the screen for options, you can Group by various headings depending on the Notification you are viewing Double click on an entry in the list to open the client details. Page 12
Notifications for Partners and Fee Earners Clients Awaiting Money Laundering notification will display all clients who have an open case file and no Money Laundering details entered. Clients missing AML in either primary or secondary notification will show any client who has missing verification details in either section Client High Risk Assessments (CDD) notification will only include active clients that are marked as being either a PEP or as having supplied non-original ID who have not been marked as Approved by the MLRO. Case File High Risk Assessments (CDD) notification will only include active case files that either have incomplete risk assessment or have been referred to the MLRO. Case Files with Activities without complete valid ML and CDD notification has been changed to include case files belonging to active clients that are marked as being either a PEP or as having supplied non-original ID who have not been marked as approved by the MLRO or active case files belonging to active clients without valid money laundering. Case Files that have not had CDD completed notification will show the number of Case Files where the Risk Assessment questionnaire has not been completed Notifications for the MLRO To help the MLRO manage the Client and Case File Risk Assessment effectively they should tick the following notifications in the productivity centre: Case Files approved by MLRO This will inform the MLRO about active case files that have been approved. This notification has a date cut off that can be changed by the user so that the list of case files approved by the MLRO doesn t continually grow. Case Files rejected by MLRO This will inform the MLRO about active case files that have been rejected. Case Files awaiting MLRO Authorisation This will inform the MLRO about active case files that are awaiting approval. These are case files that have either incomplete risk assessment s or risk assessments with high score answers for one or more questions exceeding the threshold whom the MLRO has not yet approved or rejected. Client High Risk Assessments (CDD) notification will only include active clients that are marked as being either a PEP or as having supplied non-original ID who have not been marked as Approved by the MLRO. Page 13
Notes Page 14