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

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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

Top example risks

Showing the top 7 of 32 scored factors. Pre-seeded factors you can edit, remove or add to in Excel. Residual is the category position after example controls.

The seven highest inherent risks of ten ranked in the Payments and e-money worked example
Risk factorScoreInherentResidualTheme
AI-enabled document fraud and identity circumvention16Very highMediumDelivery channels
Unusual or excessively complex ownership structures16Very highMediumCustomers
Cross-border movement of funds16Very highMediumTransactions
Fraud proceeds and mule activity16Very highMediumTransactions
Countries subject to sanctions or embargoes15HighMediumCountries or geographic areas
Non-face-to-face relationships without safeguards12HighMediumDelivery channels
Customers brought by agents and distributors12HighMediumDelivery channels
See the actual workbook · real Excel sheets, rendered from the example file

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.