Core Concepts

Module map#

Module Primary source IDs Practitioner use
Risk-Based Approach SRC-FATF-001 Decide depth of controls based on risk
CDD/KYC SRC-FATF-001 Identify, verify, understand and monitor customer
Record Keeping SRC-FATF-001 Preserve evidence for audit/law enforcement
PEP SRC-FATF-001 Apply EDD and senior approval when required
Sanctions / TFS / CPF SRC-FATF-001, SRC-UN-001, SRC-FATF-007 Freeze/no-dealing escalation and sanctions screening
Beneficial Ownership SRC-FATF-001, SRC-FATF-004, SRC-FATF-005 Identify natural persons who own or control customer
STR/SAR SRC-FATF-001, SRC-EGMONT-001 Escalate suspicion to MLRO/FIU process
Internal Controls SRC-FATF-001, SRC-BASEL-001 Policies, controls, training and independent audit
VASP / Crypto SRC-FATF-001, SRC-FATF-003 Crypto exposure, VASP licensing and Travel Rule context
TBML SRC-FATF-006 Trade finance and goods-flow risk indicators

Core operating rules#

Risk-Based Approach#

The reviewer should allocate effort based on identified risk. Higher risk requires enhanced measures. Lower risk may allow simplified measures only where implementation policies and risk assessment permit it.

CDD/KYC#

The reviewer must understand who the customer is, who owns or controls the customer, why the relationship exists, and whether activity remains consistent with the customer risk profile.

Record keeping#

The reviewer should preserve enough evidence to reconstruct what was checked, which sources were used, what was found, what was missing, who reviewed it and why the decision was made.

PEP#

The reviewer must not treat all PEPs as automatically prohibited. It should identify PEP type, role, geographic/organisational context, risk relevance, source of wealth/source of funds needs, senior approval needs and monitoring intensity.

Sanctions / TFS / CPF#

The reviewer must treat sanctions hits as time-sensitive. Possible matches require controlled escalation. Likely or true matches require MLRO/legal process under applicable sanctions obligations.

Beneficial ownership#

The reviewer must identify natural persons behind ownership and control. If ownership is complex or opaque, the reviewer must document the chain and escalate unresolved control risk.

STR/SAR#

The reviewer should not decide final filing alone. It should assemble facts, chronology, red flags and evidence for MLRO review.

Internal controls#

The reviewer should support repeatability: every check should be explainable, logged and quality-reviewable.

Digital Jurisdiction Exposure#

Digital Jurisdiction Exposure is a practical KYB/EDD module. It reviews public domain, DNS and email infrastructure records for jurisdictional references that may not be visible from website IP geolocation alone.

It is not a traditional FATF-mandated standalone AML check. It is a supporting risk-based indicator used to enrich KYB/EDD analysis and evidence packs.

Related article: Digital Jurisdiction Exposure

Industry-practice risk-based layer#

SRC-WOLF-003 complements the FATF risk-based framework with practical financial-institution guidance on proportionality, prioritisation and effectiveness. It is a secondary industry-practice source and must remain subordinate to applicable law, FATF standards and institution-specific risk governance.