Risk scoring and adjustment
Every customer carries a risk level of Low, Medium or High, computed by the engine — never typed. Officers can propose to move a level between High and Medium, or up from Low, with reasons and a signature. No one can set Low by hand.
Who may do it: the engine computes · Maker (propose an adjustment) · Checker and Approver (sign, by direction) · Risk Manager (owns institution additions to the reference registers) · Compliance Officer (proposes prohibited-list entries) · Head of Compliance (approves them) · Internal Audit (read).
Step 0 — state authority
Section titled “Step 0 — state authority”A match on FREEZE-04, FREEZE-05, HR-03 (where it is in the institution’s obligations) or a sanctioned country is decided by the state, not scored: an applicant is refused, a customer’s account is locked. See Restrictions and orders.
Step 0b — institution policy
Section titled “Step 0b — institution policy”A confirmed match on the institution’s external sanctions list refuses an applicant and makes an existing customer High, with the reason “institution policy” — and no restriction of any kind, because the institution has no legal ground to restrict the account. The prohibited customer list refuses applicants only.
Step 1 — High
Section titled “Step 1 — High”A customer is High when they are a Foreign PEP, or when any risk factor scores:
| Factor | Scores when |
|---|---|
| High-risk country | A country in any address, nationality or income-source field is on the high-risk list |
| Special zone | Any address is in a designated special zone, read from the postcode data set |
| Domestic PEP | Domestic or international-organisation PEP, immediate family or close associate |
| Non-resident | A foreign national living outside Thailand or without a verified Thai address |
| High-risk occupation | The occupation or business type is on the institution’s high-risk list |
An applicant who declares political status is High at once. Unclear income is a flag with no score: it is shown to the officer, who may propose an upgrade.
Step 2 — Low
Section titled “Step 2 — Low”Only a customer with no score and no foreign-PEP flag is checked against the closed list: government bodies and state enterprises, named charitable foundations, specialised financial institutions, listed companies, provident and mutual funds, foreign government bodies and listed companies in jurisdictions that are not high-risk, and low-risk products. The match is held until an officer verifies the evidence; until then the customer is Medium.
Step 3 — Medium
Section titled “Step 3 — Medium”Everyone else is Medium — the baseline for an ordinary retail customer.
Reference registers
Section titled “Reference registers”The risk reference screen shows seven panels in the order the engine reads them: what each register is, its version or date, when it was loaded, how many entries it holds, and whether it is the platform baseline or the institution’s own policy.
- Platform baseline — public FATF and AMLO data, the same for every institution and read-only to all of them. A daily check reads the FATF lists; a change takes effect after the platform approves it.
- Institution additions — countries, occupations and PEP categories the institution adds under its own policy, imported by its Risk Manager and labelled “institution policy” wherever they match. They can add, never remove or weaken.
- Prohibited customer list — proposed by the Compliance Officer, approved by the Head of Compliance, readable only by the compliance roles and Internal Audit. Removing a name needs a signed reason; the row stays with its reason and date.
Adjusting a level by hand
Section titled “Adjusting a level by hand”- Maker picks the customer and checks the current data.
- Choose the proposed level, write the reason and press Propose adjustment.
- The signers on the route shown — set by the direction of the change — endorse or return it.
| Change | Signed by |
|---|---|
| High ↔ Medium | Approver |
| Low → Medium or High | Checker |
An approved adjustment holds until the next periodic review, or until a factor that scored nothing at approval starts to score.
What the system does or refuses
Section titled “What the system does or refuses”- No one sets Low by hand. Low comes only from the closed list and a verified fact.
- No downgrade while a confirmed match stands — refused at the proposal and again at the signature. The way down is to clear the match by the route it came in by.
- No override button exists for a state-authority match.
- One engine for both licence types. A DA Dealer’s higher product risk is carried by its added steps — EDD events, mule tiers, the pattern gate and transaction monitoring — not by a factor in the customer’s score.