Step 02 / Explore the workbook

See the risks. Understand the controls.

A visual view of what is inside the Insurance and mortgage intermediaries edition, before you open Excel. Choose a tab to explore the illustrative worked example.

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Insurance and mortgage intermediaries

Financial crime risk assessment · illustrative example firm: Wrenfield Cove Intermediaries Limited

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33
Pre-seeded risk factors: 5
Risk categories: 02
High or very high inherent risks: 00
Categories above appetite

bwra-insurance-mortgage-worked-example.xlsxIllustrative data

Illustrative control catalogue

Each control is rated for design and operating effectiveness, with the evidence behind the rating. Showing the 7 weakest of 13.

Proliferation financing assessment and controls25%High Weak
Mitigates: Countries or geographic areas, Transactions, Products or services
Design 2 / operating 1
Policy statement only.
Enhanced due diligence and PEP handling50%Medium Adequate
Mitigates: Customers, Countries or geographic areas, Transactions
Design 3 / operating 2
EDD process exists; few cases to evidence effectiveness.
Transaction monitoring and scrutiny50%Medium Adequate
Mitigates: Transactions, Countries or geographic areas, Customers
Design 2 / operating 2
Manual review of unusual premiums; no automated monitoring.
Independent audit and compliance monitoring50%Medium Adequate
Mitigates: Customers, Countries or geographic areas, Products or services, Transactions, Delivery channels
Design 2 / operating 2
Compliance monitoring plan covers AML but no independent audit.
New product and technology risk assessment50%Medium Adequate
Mitigates: Products or services, Delivery channels
Design 3 / operating 2
Product approval includes a financial crime check.
Third-party, agent and outsourcing oversight50%Medium Adequate
Mitigates: Delivery channels, Customers
Design 2 / operating 2
Introducer agreements in place; limited oversight.
Customer due diligence (identification, verification, purpose)75%Low Strong
Mitigates: Customers, Products or services, Delivery channels
Design 3 / operating 3
Documented identity and source-of-funds checks for all clients.

Controls in the Insurance and mortgage intermediaries worked example
Control area	Mitigates	Design / operating	Strength	Example evidence
Proliferation financing assessment and controls	Countries or geographic areas, Transactions, Products or services	2 / 1	25%High Weak	Policy statement only.
Enhanced due diligence and PEP handling	Customers, Countries or geographic areas, Transactions	3 / 2	50%Medium Adequate	EDD process exists; few cases to evidence effectiveness.
Transaction monitoring and scrutiny	Transactions, Countries or geographic areas, Customers	2 / 2	50%Medium Adequate	Manual review of unusual premiums; no automated monitoring.
Independent audit and compliance monitoring	Customers, Countries or geographic areas, Products or services, Transactions, Delivery channels	2 / 2	50%Medium Adequate	Compliance monitoring plan covers AML but no independent audit.
New product and technology risk assessment	Products or services, Delivery channels	3 / 2	50%Medium Adequate	Product approval includes a financial crime check.
Third-party, agent and outsourcing oversight	Delivery channels, Customers	2 / 2	50%Medium Adequate	Introducer agreements in place; limited oversight.
Customer due diligence (identification, verification, purpose)	Customers, Products or services, Delivery channels	3 / 3	75%Low Strong	Documented identity and source-of-funds checks for all clients.

See the actual workbook · real Excel sheets, rendered from the example file

Insurance and mortgage intermediaries: Inherent risk heatmap with category scores (illustrative example)

Risk heatmap · opens full size

Insurance and mortgage intermediaries: Residual risk dashboard against risk appetite (illustrative example)

Residual dashboard · opens full size

Insurance and mortgage intermediaries: Top ten inherent risks with rationale (illustrative example)

Top risks · opens full size

Insurance and mortgage intermediaries: Controls assessment with design and effectiveness ratings (illustrative example)

Controls summary · opens full size

Built from the same data and formulas as the worked-example workbook, for an invented firm. All figures are illustrative.

About the Insurance and mortgage intermediaries edition

Insurance and mortgage intermediaries, including life and protection advisers. Insurance intermediaries are within the Regulations when acting in respect of long-term insurance contracts (reg 10(2)(f)). Mortgage intermediaries are not named in that definition, so confirm with your supervisor whether you are a relevant person; the method still supports your financial crime risk assessment. The NRA 2025 rates the insurance sector as low risk for money laundering, with higher risk in investment-type life products.