AML Network Risk Rating

What the rating measures

Every entity listed in the Watchdog Databases carries a risk rating. The rating summarises that entity's public regulatory record: what sanctions authorities, financial supervisors, prosecutors and courts have placed on record about it, and what authorisations it holds. It is compiled from documents already in the public domain — sanctions listings, licence and registry extracts, enforcement notices, indictments and judgments, asset seizure and forfeiture records, and published findings of financial intelligence units and supervisory bodies.

The rating is descriptive rather than predictive. It records what has already happened; it does not forecast whether an entity will be involved in money laundering, and it does not replace the customer due diligence a regulated firm must perform under the FATF Recommendations as implemented locally, the EU AMLD and AMLR framework, the US Bank Secrecy Act or the UK Money Laundering Regulations.

The three tiers

We publish three tiers. They describe the weight of the public record, not our opinion of an entity's character or intentions.

No Risk. Nothing adverse on the public record. Where the entity's activity requires authorisation, it is licensed or registered with a competent authority and remains in good standing under active supervision.
Low Risk. Something is on record that falls short of formal action: a lapsed, restricted or surrendered registration; supervisory findings closed without penalty; an unresolved regulatory query; or exposure through ownership or control to an entity rated higher.
High Risk. Formal adverse action is on record: a sanctions designation, a criminal indictment or conviction for a laundering or predicate offence, asset seizure or forfeiture, licence revocation or suspension, or a substantive enforcement penalty imposed by a supervisor.

What moves an entity between tiers

Ratings move on documents, not on allegation or press reporting alone. The categories of evidence we weigh are:

Sanctions designations by a national or supranational authority, including designation of a controlling owner or parent.
Criminal process — indictments, charges laid, convictions and sentencing, and deferred prosecution or settlement agreements entered on the record.
Seizures and forfeitures ordered or executed against the entity's assets.
Regulatory enforcement — financial penalties, public censures, imposed licence conditions, suspension and revocation.
Licensing and supervision — evidence pointing the other way: an authorisation in good standing, a completed remediation, a lifted restriction, a delisting, an acquittal or a dismissed case.

Evidence in the second direction is applied as readily as the first. Removal from a sanctions programme, a quashed or overturned conviction, or the expiry of a time-limited enforcement measure will move an entity down the scale.

A rating is not an accusation

A High Risk rating states that a competent authority has taken a step that is a matter of public record. It does not assert guilt beyond what a court has determined, and it does not attribute conduct to an entity's directors, employees, customers or counterparties. Designation, charge and investigation are not findings of fact against a person, and entities are entitled to the presumption of innocence throughout.

Neither is a rating advice. It is not a screening decision, a recommendation, or in itself a proper basis for opening, refusing or terminating a business relationship. Those judgements belong to the regulated firm and its own risk framework.

Review and currency

Sanctions sources are re-checked continuously against the databases, and every listing is reviewed in full at least once every twelve months. A review is also triggered outside that cycle by new adverse evidence, by a change in an entity's authorisation status, by a reader report, or by a request for correction. Each listing shows the date it was last reviewed; where that date is old, treat the entry as a pointer to primary sources rather than a current position.

Known limitations

Disclosure varies by jurisdiction. Entities operating where registers are thin or enforcement is unpublished are systematically under-represented. An absence of adverse record is not evidence of good conduct.
Identity matching is imperfect. Common personal and company names, transliteration differences and reused registration numbers can produce mismatches.
Records lag events. Publication of judgments, licence changes and enforcement outcomes can trail the decisions themselves by months.
Group structures blur attribution. Where beneficial ownership is opaque, action taken against one company in a group may or may not be properly read across to another.
Three tiers compress detail. A procedural penalty and a laundering conviction can both sit in High Risk. Always read the listing, not only the label.

Requesting a correction

Any entity, or a representative acting for one, may ask for a rating to be reviewed. Write to support@amlreview.co with the exact listing name and page address, the specific statement in dispute, and supporting documents — a delisting notice, a court order, a current licence or a registry extract. We give weight to primary documents from the issuing authority.

We aim to acknowledge requests within five working days and to complete a review promptly thereafter. Where the record is wrong, we correct or remove the entry and note the change. Where we retain a rating, we explain which documents it rests on, and an entity may submit a short factual statement of response for publication alongside its listing. We do not remove accurate records of public regulatory action, but we will always correct how those records are described.