Pax2Pay Customer Risk Assessment Form (B2B Only)
I. Customer Identification & Verification
Assessor Name:
Corporate Details
Full Legal Name of Company/Entity:
Company Registration Number/ID:
Date of Incorporation/Registration:
Registered Address:
Business Activity/Industry:
Website (if applicable):
UBOs, Directors, Senior Management Details (Names, Roles, Ownership %):
Purpose and Nature of Business Relationship:
Anticipated Source of Funds (for funding Pax2Pay accounts):
Anticipated Destination of Payments:
II. Financial Crime Risk Factors
Customer Type Risk:
Low Risk (e.g., Publicly listed, Regulated FI)
Medium Risk (e.g., Regulated higher-risk sectors, new business)
High Risk (e.g., Cash-intensive, unregulated, shell company)
Geographic Risk:
Low Risk (e.g., UK, EU, US)
Medium Risk (e.g., Moderate ML/TF risk regions)
High Risk (e.g., FATF High-Risk Jurisdictions, Sanctioned)
PEP & Sanctions Screening:
No Hit (Neither PEP nor Sanctioned)
PEP Hit (Customer/UBO is a PEP)
Sanction Hit (Customer/UBO is Sanctioned)
Adverse Media / Negative News:
Clean (No significant negative news)
Minor (Minor issues, resolved allegations)
Significant (Financial crime, fraud, corruption related)
Payment Methods Utilised Risk:
Low Risk (e.g., Virtual cards for known suppliers)
Medium Risk (e.g., Virtual cards for high-value/frequent changes)
High Risk (e.g., Large international bank transfers to diverse beneficiaries)
Transaction Patterns & Volume Risk:
Low Risk (Consistent, predictable patterns)
Medium Risk (Moderate volumes, some variations)
High Risk (Unusually high volume/value, rapid turnover, complex layering)
Delivery Channel Risk:
Low Risk (Direct API Integration)
Medium Risk (Pax2Pay Web Portal)
High Risk (Partner/Third-Party Platform)
Complexity of Corporate Structure & Ownership:
Low (Simple, transparent structure, clear UBOs)
Medium (Some layers, but UBOs identifiable with reasonable effort)
High (Complex, opaque structures, multiple jurisdictions, nominee shareholders, difficulty in identifying UBOs)
III. Consumer Duty Considerations
Product/Service Suitability & Needs Alignment:
Good (Pax2Pay services clearly align with customer's stated needs and business model)
Moderate (Some aspects of service usage might not perfectly align, requires further review)
Poor (Significant misalignment or potential for customer detriment)
Transparency of Fees & Charges:
High (All fees/charges clearly communicated and understood)
Medium (Minor ambiguities or potential for misunderstanding)
Low (Significant lack of clarity, hidden fees, or complex structures)
Customer Understanding & Communication Clarity:
High (Customer demonstrates clear understanding of services, risks, and terms)
Medium (Some areas of potential misunderstanding, requires additional explanation)
Low (Significant lack of understanding, complex jargon, or misleading information)
Vulnerability Indicators (for small businesses/sole traders):
None Identified
Minor (e.g., basic language barrier, limited digital literacy/resources)
Significant (e.g., severe financial distress, significant resource limitations)
Customer Support & Post-Sale Service Effectiveness:
Excellent (Proactive, responsive, clear support channels)
Adequate (Standard support, some delays or less personalized)
Poor (Difficult to access support, unresolved issues, negative feedback)
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Calculated Risk Score:
Risk Level: