Risk Assessment · 23 June 2026 · 4 min read
Matter Risk Assessment: The Other Half of the AML Picture
The same client can present very different AML risk across two instructions. Client and matter risk assessment should work together.
A client's identity does not tell you everything about the risk created by a particular instruction.
The same client can instruct a firm on two matters with very different AML characteristics.
Consider the difference between a routine advisory instruction and a transaction involving:
- unusual payment arrangements
- third-party funding
- high-risk jurisdictions
- complex corporate structures
- significant movement of funds
- unexpected changes in transaction behaviour
The client may not have changed. The risk presented by the matter may have.
That is why client risk assessment and matter risk assessment should work together.
A useful matter risk assessment should encourage the fee earner and AML team to consider what is actually happening, why it makes commercial sense and whether the proposed activity changes the firm's exposure.
Note on sources: General practitioner commentary rather than regulatory guidance. Align matter risk assessment design with current UK legal-sector AML requirements and your own risk-based procedures.
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