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Customer risk rating matrix

A customer risk rating matrix for financial crime: factors, scoring, overrides and outcomes, what an AI agent may calculate, and a filled example.

A customer risk rating matrix scores a customer's financial crime risk across set factors, such as customer type, geography, products, channel, activity and screening results, then combines them into a rating of low, medium or high, with overrides for cases that are always high. An AI agent can calculate each factor and show its working. A person sets the rating.

What does the matrix do?

A customer risk rating decides how much due diligence a customer receives, how often their file is reviewed and how closely their activity is monitored. It is the practical form of the risk-based approach in the FATF Recommendations. The matrix makes the rating consistent: the same facts produce the same score, whoever looks.

It also makes the agent's role clear. Scoring factors from data is mechanical work an agent can do accurately. Deciding what a combination of facts means, and whether an override applies, is judgement. Whether an AI agent can decide a customer's risk rating answers the question directly: it can calculate, a person decides.

When should it be applied?

At onboarding, at each periodic review, and when a trigger event changes a factor: a new country in the customer's payments, a screening hit, a change of business. The review process itself is covered in how to run customer risk rating reviews with an AI agent.

How do you build and fill the matrix?

  1. Choose factors that reflect your business and your own risk assessment. Six to eight is usually enough.
  2. Define low, medium and high for each factor in words, with examples. Avoid vague terms like "unusual".
  3. Assign scores to each level, and decide how scores combine: a total, or the highest factor wins, or a mix.
  4. Set overrides: facts that make a customer high risk whatever the score, and facts that require a person to set the rating even if the score is low.
  5. Set outcomes: what each rating means for due diligence, review cycle and monitoring.

The agent fills in a factor sheet for each customer: level, score, and the evidence behind it with provenance. The analyst reviews the sheet, applies overrides and sets the rating.

The customer risk rating matrix

Part A: factors

Factor Low (score) Medium (score) High (score)
Customer type
Geography
Products and services
Delivery channel
Expected activity
Industry or occupation
Screening

Part B: combination and overrides. How scores combine; automatic high-risk overrides; cases always referred to a person.

Part C: outcomes

Rating Due diligence Review cycle Monitoring
Low
Medium
High

A filled example: business banking

Part A (extract)

Factor Low (1) Medium (2) High (3)
Customer type Limited company, simple ownership Partnership; sole trader Trust; layered ownership
Geography Domestic only Trade with lower-risk foreign countries Links to higher-risk countries on your list
Industry Professional services Retail; hospitality Cash-intensive; money services; precious goods
Expected activity Matches turnover Seasonal swings Turnover inconsistent with business
Screening No hits Adverse media, not financial crime PEP link; financial crime media

Part B. Total of seven factors: 7 to 10 low, 11 to 15 medium, 16 and above high. Any sanctions-related hit, or a direct PEP, is high regardless. Any PEP link or trust structure is referred to an analyst before rating.

Factor sheet for a hypothetical sole trader running a car wash:

Factor Level Evidence
Customer type Medium Sole trader (registry, signed)
Geography Low Domestic only (transactions, signed)
Products Low Current account only
Channel Low Onboarded in branch
Expected activity Medium Weekly cash deposits, seasonal
Industry High Cash-intensive
Screening Low No hits

Total 12: medium. No override. The analyst accepted medium, noting the cash pattern matched the business, and set monitoring rules for cash deposits above the expected weekly range.

How does this relate to other matrices?

Financial crime risk is not the same as conduct risk. A customer can be low risk for money laundering and still be vulnerable, which affects how they should be treated; whether an AI agent can review customer calls for conduct risk covers that side. Complaints are classified on their own matrix, the complaint classification matrix. The wider boundary is set out in AI compliance agents: second line, never the last word.

Questions people ask

Should the agent's score be the default rating?

It can be shown as the calculated score, but the analyst sets the rating. Record both, and record the reason whenever they differ.

How often should the matrix itself be reviewed?

At least once a year, after your business-wide risk assessment, and whenever you add products, channels or markets.

Can the agent lower a rating at review?

It can show that factors have improved. Lowering a rating reduces scrutiny, so that decision should always be a person's.

Decide what your agents may do. Prove it. Enforce it.

Pryme Intelligence certifies each agent on your own cases, checks every action against five bounds at the moment it happens, and files every verdict.