Methodology
Five risk domains
- Client / Customer / Vendor30%
- Channel / Distribution15%
- Geographical20%
- Transaction20%
- Products / Services15%
Relationship-type modifiers can shift emphasis (e.g. intermediaries weight channel risk higher). Weights are not user-editable in V1.
Scoring bands
- Low0–19
- Medium-Low20–39
- Medium40–59
- High60–79
- Very High80–100
Three mechanisms
Each domain aggregates its factors (strongest in full, second 50%, others 25%); domains combine by weight into inherent risk. Completed mitigations reduce domain scores proportionally (max 55%).
Confirmed sanctions match → Sanctions / Legal Review, outside scoring. Relevant PEP → mandatory PEP review, SoW, SoF and senior approval. PEP alone never means Very High.
Unresolved UBO → minimum High (or unable to conclude for UBO-critical relationships). Unexplained third-party funding → minimum High. Unresolved identity or material evidence conflict → unable to conclude.
Associated-subject propagation
Findings propagate as Severity × Relationship Materiality × Relevance × Attribution. Scores are never averaged.
- UBO (70%)0.88
- Controlling Person0.90
- Shareholder (70%)0.57
- CEO / Managing Director0.80
- Chair0.65
- Director0.40
- Authorised Representative0.55
- Signatory0.50
- Parent Entity (70%)0.81
- Associated Entity0.30
- Former Director0.15
Finding materiality
Each adverse, regulatory, criminal or litigation finding is assessed on severity, legal stage, recency, outcome, resolution, recurrence, relationship relevance, identity attribution and evidence confidence. Age reduces but never removes a serious conviction; favourable resolution strongly reduces; recent ongoing very serious matters stay High while clearly labelled as allegations or investigations. Original facts are never rewritten. Information that cannot be attributed is recorded as Unable to Verify and is never scored as a confirmed adverse finding.
Who is behind the methodology
Andréas Hobbelin — AML compliance and EDD expert with over 15 years of experience and thousands of Enhanced Due Diligence reviews.
Background as EDD expert and investigator in audit and consulting (BDO Forensic Services), senior AML officer in banking (Swedbank Group), Head of AML & Financial Crime Prevention at Nordic fintechs (ZTL, Plusius), and further assignments at banks and fintechs.
A leading AML compliance expert in the Spanish real estate sector, where high-risk non-residents (HRNR), high-net-worth and ultra-high-net-worth individuals buying or selling property are subject to EDD every day. Real estate professionals are a core user group, with their buyer and seller clients as subjects.
Ai Risk Intelligence AS · Org. no. 833854992 · C. Piñon, 29639 Benalmádena, Málaga, Spain · LinkedIn
Risk factor library
- PEP exposure
- Adverse finding
- Identity uncertainty
- Complex or opaque ownership
- UBO unresolved
- Source of Wealth partly unresolved
- Source of Funds partly unresolved
- Higher-risk business activity
- Remote onboarding with limited controls
- Introducer / intermediary reliance
- Power of attorney
- Residence / incorporation jurisdiction
- Nationality / citizenship jurisdiction
- Tax residence jurisdiction
- Operating / HQ jurisdiction
- Geographic structure mismatch
- Jurisdictional exposure
- Sanctions-exposed jurisdiction
- High-value transaction
- Third-party payment
- Cash funding
- Crypto-asset funding
- Complex / offshore payment routing
- Cross-border relationship
- Product / service risk characteristics
- Control over money or assets
- High transaction velocity
- Nested payment relationships
- Merchant settlement risk
- Client money through firm account
- Company formation service
- Trust / fiduciary structures
- High-value property transaction
- Third-party buyer / payer
- Opaque holding vehicle