New Client & Matter Risk Assessment

This question is about any concerns that may increase AML risk, even if they are not definitive or have already been mitigated.

Consider whether there are concerns relating to:

• The client’s capacity or vulnerability (for example age, illness, reliance on others, pressure or influence)
• The client’s location in context, including whether it makes sense for the client to be instructing the firm from that location, or whether instructions are being given from somewhere unexpected or inconsistent with the client’s profile
• Any agent, introducer, intermediary, or third party involved in the client relationship
• Anything that feels unusual, inconsistent, or unclear about the client or how instructions are being given

This is not limited to confirmed issues. If something has caused hesitation, uncertainty, or requires explanation, answer Yes.

If there are no such concerns, answer No.

Riskivo does not perform screening checks. This section records the outcome of screening already carried out by your firm using your existing providers (for example sanctions, PEP, and adverse media screening).

Riskivo relies on these inputs to assess AML risk and determine whether Enhanced Due Diligence (EDD) is required.

You should:

• Answer these questions based on your firm’s screening results
• Record the highest relevant outcome where multiple results apply
• Ensure screening has been completed in line with your firm’s policies before proceeding

Riskivo uses this information to evaluate risk and generate a regulator-ready assessment, but screening responsibility remains with your firm.

Third-party funds means any money connected to the matter that comes from someone other than the client. This includes fees, retainers, settlements, escrow or transaction funds paid by:

• Directors or shareholders personally
• Parent or group companies
• Insurers or litigation funders
• Family members, trusts, SPVs or other connected parties

It does not matter if the third party is known, reputable, or related. If the money passes through the client account or is relied on to fund the matter, answer Yes.

Third-party funding increases AML risk because it can obscure the true source of funds. Legal Sector Affinity Group treats this as a risk escalation factor, not a neutral fact.

Answer No only where the client (the same legal person or entity) pays from its own account. If Yes, the firm must record who the third party is, their relationship to the client, and why they are funding the matter. This does not always require full CDD, but it does require a documented assessment.