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2.2.5. Geographic Risk Factors

Effective from 31/10/2022

A customer’s geographic location or connections may indicate a higher risk for ML/FT activities. To mitigate risk, controls are recommended based on domestic and international geographic risk factors. Where available, data from internal insurer historical case experiences or government data based on crimes applicable to ML or predicate offenses can be used to inform the assessment of domestic geographical risk. Customer risk is higher among customers with connections outside the country, especially connections to higher-risk countries. According to the National Assessment of Inherent Money Laundering and Terrorist Financing Risks in the United Arab Emirates, the regions and jurisdictions most often involved in criminal activity in relation to the UAE were Pakistan, India, Iran, Bangladesh, China, Russia, South Africa, Nigeria, Somalia, Lebanon, Yemen, Syria, Iraq, Afghanistan, and North Africa. The following table describes attributes used to assess geographic risks and provides each's lower- and higher-risk examples.

AttributeLower-risk exampleHigher-risk example
Higher-crime regionsCustomer does not reside in a region with higher frequency and severity of crimes with ML risk, based on the insurer’s own risk assessment (utilizing historical case experiences or government data where appropriate)Customer resides in a region with high frequency and severity of crimes with ML risk, based on the insurer’s own risk assessment (utilizing historical case experiences or government data where appropriate)
History high-risk activity or fraudCustomer does not reside in a region that experiences a higher incidence of high-risk activity or fraudCustomer resides in a region that experiences a higher incidence of high-risk activity or fraud
Foreign tax or physical residency of customerCountries risk rated as low by the insurerCountries risk rated as high by the insurer
Foreign ties or transactionsCustomer does not have any indicators of foreign residency or transactions outside of countryCustomer has requested or performed transactions with ties to high-risk countries, including especially those on the NAMLCFTC’s and FATF’s lists of high-risk jurisdictions subject to a call for action and jurisdictions under increased monitoring.