AML risk assessment of a client

How the tool works

1. Scope. You say what your work in the matter involves. The transactions of art. 5 §1 28° of the Law of 18 September 2017 bring the matter within scope: buying or selling real estate or a business, managing the client's funds, securities or accounts, organising contributions, creating or managing companies, fiducies or trusts, and acting in the client's name in a financial or real-estate transaction. Litigation, legal advice and judicial mandates are outside it: the tool then makes a dated note that explains why, with the duties that apply to every matter.
2. Mandatory cases. A link with a high-risk third country on the EU or FATF lists (art. 38), with a state with no or low taxation (art. 39), or a politically exposed person (art. 41) makes enhanced due diligence mandatory. The tool applies these cases first: no favourable factor offsets them.
3. Factors. You tick the factors of Annexes I to III you observe in the matter, by category (client, product or transaction, delivery channel, geography), and, if you wish, the factors the bars use in their public templates.
4. Level. Low, standard or high, with its reasons: the rule applied and the factors that triggered it. A missing answer never leads to a low level. You may raise the level with a reason, never lower it.
5. Measures. Identification and verification of the client, the agents and the beneficial owners, the UBO register, the purpose of the relationship, PEP and financial-sanctions screening, the source of funds and ongoing monitoring: you mark each one done, to do or not applicable.
6. The file note. Dated, in the language you choose, with the matter reference and the client's name typed for the document only, the factors, the level and its reasons, the measures and their state, and the signature line.

Legal basis

• Law of 18 September 2017: art. 5 §1 28° (scope), art. 19 (individual assessment), arts. 21 to 35 (due diligence), arts. 37 to 41 (enhanced due diligence), art. 60 (10-year retention) and Annexes I to III (risk factors).
• Constitutional Court, judgment 114/2020 of 24 September 2020: professional secrecy and the line between advice and transaction.
• AVOCATS.BE Code of conduct, arts. 4.85 to 4.89; OVB Codex Deontologie, arts. 67 to 73 and annex 1.

Points to check

• The rating method (categories, major factors, overall level) is a proposal based on the law, to be reviewed by the lawyer. The law requires an assessment and measures that fit the risk, not a points grid.
• The country lists are those read on the FPS Finance page on 7 October 2026. They change several times a year: check them for every new matter. An EEA member state on a FATF list, such as Bulgaria, does not trigger art. 38.
• The list of states with no or low taxation of art. 39 is not reproduced in the tool: check it before answering.
• A suspicion is reported to the bâtonnier (art. 52), never through the tool. It is not printed on the file note.
• From 10 July 2027, Regulation (EU) 2024/1624 applies directly; the tool will be updated.

Data and vault

Your answers stay in your browser: nothing is sent, neither in the page address nor in a statistic. With a verified e-mail address, you keep your notes in an encrypted vault on this device and your documents carry the firm's letterhead. The firm's overall risk assessment is prepared with the firm-wide assessment tool.

Verification

The rules were verified on 7 October 2026 against the consolidated text of the law and the bars' rules. The tool assists the lawyer, who remains responsible for the assessment and the measures taken.