The circular said:
On a number of occasions, it was observed that the AML/CFT risk assessments were not reviewed to evaluate whether they needed adjustment upon subsequent changes of the customers’ risk profiles. As a result, the assessment of the customers’ ML/TF risks was not up to date and therefore CDD and ongoing monitoring was not always effective or as effective as they could have been.
CySEC did not reveal the names of any of the firms where it found those regulatory lapses.
CySEC noted:
Regulated entities need to be making constant and continuous efforts to ensure processes to prevent ML/TF are adequate. The consequences of failing to manage risks associated with ML/TF are serious and cause damage not only to Regulated Entities, but to the financial system as a whole.
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