An Enterprise-Wide Risk Assessment (EWRA) is a strategic, organization-wide measure that identifies, analyzes, and monitors money laundering, terrorist financing, and related financial crime vulnerabilities across all products, services, customer segments, and geographies. By systematically reviewing both internal processes and external risk factors, financial institutions calibrate controls and resource allocations in proportion to the evolving ML/TF threats they face. This operational approach involves: (1) gathering and synthesizing relevant risk intelligence; (2) assessing inherent and residual risks for each line of business; (3) tailoring and enhancing AML/CFT measures based on the identified risk profile; and (4) maintaining a cycle of dynamic review and senior management oversight. The EWRA ultimately fosters informed, risk-based decisions, ensuring more robust detection, disruption, and prevention of illicit financial activity at an enterprise level.
Enterprise-Wide Risk Assessment
Client Lifecycle Stages
Focuses on the institution’s comprehensive ML/TF risk, typically outside specific client episodes.
Mitigated Techniques
Explicitly assess organizational structures and internal data flows to identify areas where operational silos may mask connected criminal activity. By mapping how information moves—and sometimes fails to move—between business units, financial institutions can develop cross-functional oversight processes that hinder attempts to launder funds by limiting any single team’s view.
References
MAS (Monetary Authority of Singapore). (2024). Money laundering and terrorism financing risk assessment of legal arrangements in Singapore. MAS. https://www.mas.gov.sg/publications/monographs-or-information-paper/2024/money-laundering-and-terrorism-financing-risk-assessment-of-legal-arrangements
FATF. (2021, June). Guidance on proliferation financing risk assessment and mitigation. FATF. https://www.fatf-gafi.org/publications/financingofproliferation/documents/proliferation-financing-risk-assessment-mitigation.html
Fintrail. (n.d.). Enterprise-wide risk assessment best practice. Fintrail. https://fintrail.com