YOUR customer risk assessments [CRA] CHECKLIST for the ACCOUNTANCY SECTOR

• BITESIZE REPORT = https://www.jerseyfsc.org/media/2tijyjhs/bitesize-feedback-accountancy-sector-customer-risk-assessments.pdf

As a result of this JFSC update Comsure has put together the following CRA Compliance Checklist for Accountancy Sector.

This checklist:

• Is derived from the JFSC's Bitesize Feedback on customer risk assessments in the accountancy sector (Q1 2025 review).
• Helps supervised persons evaluate and enhance their CRA processes for effective, risk-based compliance.

Use it to self-assess your onboarding and ongoing customer reviews.

• For each item, check "Yes" if implemented, "No" if not, and
• Note actions needed.

CRA COMPLIANCE CHECKLIST FOR ACCOUNTANCY SECTOR

1. Embedding Risk Appetite in Procedures

• Is your risk appetite clearly embedded within customer acceptance procedures?
• Does your CRA include well-defined risk criteria and tolerance thresholds to support consistent and transparent customer risk assessments?

2. Reviewing and Improving CRA Frameworks

• Are your CRA frameworks subject to regular periodic reviews?
• Are event-driven reviews conducted, such as after changes in jurisdictional risk ratings?
• Do reviews include documented action plans to enhance the framework's effectiveness and promote continuous improvement?

3. Considering Risk Factors Holistically

• Does your CRA incorporate a broad range of risk factors (e.g., jurisdictional, sanctions, PEPs, adverse media)?
• Have you demonstrated a clear understanding of how individual risk factors contribute to a holistic view of customer risk for informed decision-making?

4. Maintaining Complete Screening Records

• Are customer screening records complete, including clear, written rationales for discounting potential matches?
• Do records specifically address discounts related to sanctions, politically exposed persons (PEPs), and adverse media to avoid inconsistencies?

5. Explaining Risk Rating Determinations

• Does your CRA framework provide sufficient explanation of how risk ratings are determined?
• Is the assessment of jurisdictional risk well-articulated to ensure consistent factoring into overall customer risk calculations?

6. Providing Guidance in Policies and Procedures

• Do your policies and procedures offer clear, practical guidance to staff on completing CRAs comprehensively, accurately, and consistently?
• Have you minimized the risk of subjective or inconsistent assessments through detailed instructions?

7. Key Self-Assessment Questions

• Do you ensure your CRA is applied consistently and comprehensively, regardless of how well you know the customer (e.g., avoiding reliance on personal relationships in sole practices or smaller businesses)?
• Do you periodically evaluate the effectiveness of your CRA process to ensure it remains fit for purpose, identifying weaknesses and making adjustments?
• Does your CRA consider the cumulative risk a customer presents, recognizing that combined minor factors can elevate the overall risk profile beyond your risk appetite?

NEXT STEPS

• Review this checklist regularly, especially after JFSC updates or internal changes.
• If gaps are identified, develop action plans to align with observed good practices and address improvement areas.

For full details, refer to the original JFSC feedback document – see below:

• https://www.jerseyfsc.org/news-and-events/read-the JFSC-bitesize-feedback-for-the-accountancy-sector-on-customer-risk-assessments/