Skip Navigation
AML Risk Assessment and Compliance: Managing Money Laundering and Terrorist Financing Risks
AML risk assessments are a key part of meeting your compliance obligations and protecting your business from financial crime. At A2CO, we help companies assess and manage money laundering and terrorist financing risk through structured CRA development, AML model validation, and tailored risk frameworks. Whether you’re building from scratch or updating your current approach, we guide you through the full AML risk process with practical support. Our team works with businesses in Malta and across Europe to meet both local and EU-wide AML requirements.
What Is an Anti-Money Laundering Risk Assessment and Why It Matters
In Malta, all subject persons are required to assess the risk of money laundering and terrorist financing before entering into any business relationship. This process is guided by the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and overseen by the Financial Intelligence Analysis Unit (FIAU).
A well-developed AML risk assessment, particularly the Client Risk Assessment (CRA), helps determine the level of customer due diligence to apply, based on a client’s overall risk profile. It also directly informs your Customer Acceptance Policy (CAP), ensuring clients are onboarded based on their risk level and in line with internal compliance procedures. It is a fundamental part of the risk-based approach recommended by the Financial Action Task Force (FATF) and enforced by local regulation. Failing to assess and mitigate these risks can lead to supervisory action, reputational harm, and exposure to financial crime.
AML Risk Assessment and Risk-Based Frameworks for Laundering and Countering the Financing of Terrorism
What Is an Anti-Money Laundering Risk Assessment and Why It Matters
In Malta, all subject persons are required to assess the risk of money laundering and terrorist financing before entering into any business relationship. This process is guided by the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and overseen by the Financial Intelligence Analysis Unit (FIAU).
A well-developed AML risk assessment – particularly the Client Risk Assessment (CRA) – helps determine the level of customer due diligence to apply, based on a client’s overall risk profile. It is a fundamental part of the risk-based approach recommended by the Financial Action Task Force (FATF) and enforced by local regulation.
Failing to assess and mitigate these risks can lead to supervisory action, reputational harm, and exposure to financial crime.
Money Laundering Risk Categories in line with AML Regulations
The CRA considers multiple risk factors that together form a customer’s inherent risk level. These include:
-
Customer Risk: such as politically exposed persons (PEPs), cash-intensive businesses, and high-volume sectors like EMIs or payment providers.
-
Jurisdiction Risk: exposure to high-risk third countries, FATF-listed jurisdictions, or countries identified in national risk assessments (NRA).
-
Product, Service, or Transaction Risk: based on complexity, value, and payment method.
-
Delivery Channel Risk: including remote onboarding, intermediaries, or non-face-to-face interactions.
FIAU guidance also stresses the importance of aligning the CRA with your Business Risk Assessment (BRA) and internal policies and procedures to ensure effective risk mitigation. This process also supports your broader financing risk assessment obligations under national and EU AML frameworks.
How We Assess and Build a Risk Based Client Risk Assessments (CRA)
At A2CO, we specialise in developing bespoke CRA frameworks that are proportionate, documented, and aligned with FIAU expectations. Our process includes:
-
Designing a risk scoring system based on your risk appetite
-
Ensuring clear thresholds to determine the required level of CDD or EDD
-
Providing tools to document residual risk and risk profile changes over time
-
Structuring the CRA for governance approval and inspection readiness
Every CRA we build supports a risk-based AML strategy that’s practical, measurable, and defensible.
AML Model Validation and Risk Based Methodologies
We validate the risk model to ensure it is appropriate for your specific business context and complies with both national and international AML regulations. This includes:
-
Evaluating model assumptions and logic
-
Ensuring appropriate weighting of risk factors
-
Mapping against internal controls to assess residual risk
-
Aligning to the broader risk assessment process used in your BRA
Our aim is to ensure your CRA withstands scrutiny from the FIAU or other supervisory authorities.
Using Templates and Frameworks for Anti-Money Laundering and Countering of Terrorism Finance
To support consistency and operational use, we provide:
-
CRA templates adaptable to different sectors (e.g. CSPs, crypto, fintech)
-
Implementation guidance and workflow support
-
Optional staff training to ensure correct application
-
Documentation for approvals and audit trails
Templates are useful, but every model we deliver is tailored. No off-the-shelf solutions.
Why AML Risk Assessments Are Crucial for Crypto, Fintech, and High-Risk Sectors
Certain sectors face a higher risk of exposure to money laundering and terrorism financing, including:
-
Crypto asset service providers (VASPs)
-
Fintech companies offering cross-border payments
-
Corporate service providers dealing with complex structures
-
Gaming and remote betting operators
These businesses require more detailed CRA models, often involving enhanced due diligence, screening tools, and heightened monitoring.
Our team has direct experience building CRA frameworks in these environments and helping firms demonstrate controls to mitigate those risks through structured AML & KYC outsourcing solutions.
AML Risk Assessment Services in Malta
We offer CRA development and AML risk modelling to regulated businesses across Malta. Our services include:
-
AML gap assessments
-
CRA and BRA alignment
-
Methodology design
-
Training and implementation support
-
Preparation for FIAU inspections or remediation
We work closely with your compliance team to ensure your risk model reflects your actual exposure and operations and not just a theoretical framework.
What Is an Anti-Money Laundering Risk Assessment and Why It Matters
In Malta, all subject persons are required to assess the risk of money laundering and terrorist financing before entering into any business relationship. This process is guided by the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and overseen by the Financial Intelligence Analysis Unit (FIAU).
A well-developed AML risk assessment – particularly the Client Risk Assessment (CRA) – helps determine the level of customer due diligence to apply, based on a client’s overall risk profile. It is a fundamental part of the risk-based approach recommended by the Financial Action Task Force (FATF) and enforced by local regulation.
Failing to assess and mitigate these risks can lead to supervisory action, reputational harm, and exposure to financial crime.
Money Laundering Risk Categories in line with AML Regulations
The CRA considers multiple risk factors that together form a customer’s inherent risk level. These include:
-
Customer Risk: such as politically exposed persons (PEPs), cash-intensive businesses, and high-volume sectors like EMIs or payment providers.
-
Jurisdiction Risk: exposure to high-risk third countries, FATF-listed jurisdictions, or countries identified in national risk assessments (NRA).
-
Product, Service, or Transaction Risk: based on complexity, value, and payment method.
-
Delivery Channel Risk: including remote onboarding, intermediaries, or non-face-to-face interactions.
FIAU guidance also stresses the importance of aligning the CRA with your Business Risk Assessment (BRA) and internal policies and procedures to ensure effective risk mitigation. This process also supports your broader financing risk assessment obligations under national and EU AML frameworks.
How We Assess and Build a Risk Based Client Risk Assessments (CRA)
At A2CO, we specialise in developing bespoke CRA frameworks that are proportionate, documented, and aligned with FIAU expectations. Our process includes:
-
Designing a risk scoring system based on your risk appetite
-
Ensuring clear thresholds to determine the required level of CDD or EDD
-
Providing tools to document residual risk and risk profile changes over time
-
Structuring the CRA for governance approval and inspection readiness
Every CRA we build supports a risk-based AML strategy that’s practical, measurable, and defensible.
AML Model Validation and Risk Based Methodologies
We validate the risk model to ensure it is appropriate for your specific business context and complies with both national and international AML regulations. This includes:
-
Evaluating model assumptions and logic
-
Ensuring appropriate weighting of risk factors
-
Mapping against internal controls to assess residual risk
-
Aligning to the broader risk assessment process used in your BRA
Our aim is to ensure your CRA withstands scrutiny from the FIAU or other supervisory authorities.
Using Templates and Frameworks for Anti-Money Laundering and Countering of Terrorism Finance
To support consistency and operational use, we provide:
-
CRA templates adaptable to different sectors (e.g. CSPs, crypto, fintech)
-
Implementation guidance and workflow support
-
Optional staff training to ensure correct application
-
Documentation for approvals and audit trails
Templates are useful, but every model we deliver is tailored. No off-the-shelf solutions.
Why AML Risk Assessments Are Crucial for Crypto, Fintech, and High-Risk Sectors
Certain sectors face a higher risk of exposure to money laundering and terrorism financing, including:
-
Crypto asset service providers (VASPs)
-
Fintech companies offering cross-border payments
-
Corporate service providers dealing with complex structures
-
Gaming and remote betting operators
These businesses require more detailed CRA models, often involving enhanced due diligence, screening tools, and heightened monitoring.
Our team has direct experience building CRA frameworks in these environments and helping firms demonstrate controls to mitigate those risks through structured AML & KYC outsourcing solutions.
AML Risk Assessment Services in Malta
We offer CRA development and AML risk modelling to regulated businesses across Malta. Our services include:
-
AML gap assessments
-
CRA and BRA alignment
-
Methodology design
-
Training and implementation support
-
Preparation for FIAU inspections or remediation
We work closely with your compliance team to ensure your risk model reflects your actual exposure and operations and not just a theoretical framework.
Countering the Financing of Terrorism Through Effective AML Risk Management
A comprehensive CRA is not only about identifying money laundering risk – it is also a key tool in countering the financing of terrorism. By understanding and managing exposure to terrorist financing risk, your business contributes to Malta’s collective efforts under FATF standards and EU-wide regulation. A2CO helps you integrate this obligation into your everyday onboarding, monitoring, and reporting processes, creating a clear and defensible trail of risk analysis and mitigation.
Our Services
-
AML risk assessments tailored to your business model, services, and client base
-
Development and implementation of Client Risk Assessments (CRA) aligned with regulatory expectations
-
Validation of AML models to ensure effectiveness, proportionality, and audit-readiness
-
Risk-based frameworks to manage money laundering, terrorist financing, and sector-specific vulnerabilities
-
Compliance guidance on anti-money laundering and countering the financing of terrorism (AML/CFT) requirements
-
AML support for high-risk sectors, including crypto, fintech, gaming, and financial institutions
-
Templates, tools, and workflows to streamline your internal risk assessment process
-
Localised AML risk assessments aligned with Maltese law, EU AML regulations, and FATF standards
Why Choose A2CO
-
Practical AML advice tailored to your risk profile and regulatory obligations
-
In-depth expertise in Maltese law, EU AML regulations, and FATF-aligned frameworks
-
Proven track record in developing risk-based solutions for CRA, AML model validation, and risk mitigation
-
Full support across the entire AML risk assessment process, from strategy to implementation
-
Trusted by crypto firms, fintech companies, and regulated financial institutions across Europe
Frequently Asked Questions
An AML risk assessment identifies and evaluates the risk associated with money laundering and terrorist financing to help businesses apply a proportionate, risk-based compliance approach.
AML risk assessments should be reviewed regularly and updated when there is a change in services, client base, regulations, or identified vulnerability.
Businesses, including financial institutions, must assess customer risks, apply due diligence, monitor transactions, and maintain internal controls in line with anti-money laundering and countering regulations.
AML model validation tests whether your risk scoring or categorisation tools accurately reflect your business’s exposure to high-risk clients or transactions.
A CRA evaluates the level of risk posed by individual clients based on factors like customer type, geography, product, and delivery channel.
An AML risk assessment focuses specifically on laundering and countering the financing of terrorism, whereas a general risk assessment may cover broader operational or market risks.
