Step 02 / Explore the workbook

See the risks. Understand the controls.

A visual view of what is inside the Payments and e-money edition, before you open Excel. Choose a tab to explore the illustrative worked example.

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Payments and e-money

Financial crime risk assessment · illustrative example firm: Brindlemoor Pay Limited

Change firm type
32
Pre-seeded risk factors

Editable in your copy

5
Risk categories

Regulation 18(2)(b)

19
High or very high inherent risks

Illustrative profile

02
Categories above appetite

After example controls

bwra-payments-worked-example.xlsxIllustrative data

Inherent risk exposure

Example placement of 32 sector risks across a 5 × 5 matrix, before controls

Impact ↑

Likelihood →

LowMediumHighVery highTop ten risk, by rank
  1. 1: AI-enabled document fraud and identity circumvention, score 16
  2. 2: Unusual or excessively complex ownership structures, score 16
  3. 3: Cross-border movement of funds, score 16
  4. 4: Fraud proceeds and mule activity, score 16
  5. 5: Countries subject to sanctions or embargoes, score 15
  6. 6: Non-face-to-face relationships without safeguards, score 12
  7. 7: Customers brought by agents and distributors, score 12
  8. 8: Simple, fully remote onboarding relative to banks, score 12
  9. 9: Outsourcing and third-party delivery, score 12
  10. 10: Customers found to have provided false or stolen identification, score 12

Risks by theme

Illustrative concentration, not live firm data

  • Transactions8
  • Customers7
  • Countries or geographic areas7
  • Products or services5
  • Delivery channels5

Reading the example. Compare inherent exposure with the controls in place. Residual risk can remain material even where controls exist, and must be assessed on evidence.

Top risk drivers

  1. 01AI-enabled document fraud and identity circumventionVery high
  2. 02Unusual or excessively complex ownership structuresVery high
  3. 03Cross-border movement of fundsVery high

What the workbook calculates

Risk scores, risk ratings, control strength and residual exposure against your appetite, in this example 12.9 inherent falling to 7.2 residual. Every rating can be changed as you complete your own assessment.

Formula-led scoring
See the actual workbook · real Excel sheets, rendered from the example file
Payments and e-money: Inherent risk heatmap with category scores (illustrative example)Risk heatmap · opens full sizePayments and e-money: Residual risk dashboard against risk appetite (illustrative example)Residual dashboard · opens full sizePayments and e-money: Top ten inherent risks with rationale (illustrative example)Top risks · opens full sizePayments and e-money: 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 Payments and e-money edition

Authorised payment institutions, small payment institutions and e-money institutions. Payment and e-money firms are financial institutions under the Money Laundering Regulations. The NRA 2025 rates the EMI and PSP sector as high risk for money laundering and terrorist financing, so supervisors expect a detailed, evidenced assessment.