Comsure’s Country Risk Register is updated for all Comsure iTrack clients
Comsure’s iTrack is a sophisticated [albeit easy to use] CLIENT RISK ASSESSMENT [CRA] tool – at its heart are risk registers. One register being a HIGHER COUNTRY RISK REGISTER [copied below]
This Comsure COUNTRY RISK REGISTER has been updated following recent global events and the JFSC amendment to the appendix D2 – see below:-
- Appendix D2 – Countries and territories identified as presenting higher risks — Jersey Financial Services Commission (jerseyfsc.org)
- Increase in economic sanctions [UK/EU/OFAC] being applied to those connected to Russia [click here to read more]
- FATF adding the UAE to its ‘grey list [click here]
As part of the Comsure service all Comsure’s clients have approved the risk register [part of the governance process] and all employees have also been reminded about the following:-
- EDD files need checking and new business must collect EDD
- Where they have a client connection [directly/indirectly] with a country in this list they must act with caution.
- And where there is a proposal to transfer property/asset to/from a listed jurisdiction, refer the matter to their compliance team [trigger event] before acting.