42. The policies, controls and procedures referred to in Article 8(4) of Directive (EU) 2015/849 …

The policies, controls and procedures referred to in Article 8(4) of Directive (EU) 2015/849 should at least include the following:

• a) the business-wide and individual ML/TF risk assessment methodology;
• b) customer due diligence including that provided by the EBA revised guidelines on ML/TF risk factors¹⁹ , and a customer acceptance process as explained below in section c on Customers, in particular for high-risk customers;
• c) internal reporting (analysis of unusual transactions) and the submission of STRs to the FIU;
• d) record keeping; and
• e) provisions for monitoring AML/CFT compliance as in section d on Monitoring compliance.
• c. Customers, including high-risk customers

¹⁹ Guidelines on customer due diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions ( ‘Guidelines on ML/TF risk factors ’ ) under Articles 17 and 18(4) of Directive (EU) 2015/849: EBA/GL/2021/02

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

3. Related Standards

• EBA - Published by the European Banking Authority at https://www.eba.europa.eu/