Can an inspector see why this file is rated the way it is?
Yes, line by line. Every file is scored on your firm's own model: your categories, weights and caps, with automatic high triggers that name themselves on the breakdown. The rating sets the review cadence, reviews fall due on it, and each review records what changed, the reviewer's conclusion and who signed.
| Category | Option recorded | Points |
|---|---|---|
| Jurisdiction | Guernsey resident, GBR national | 8 |
| Structure | Discretionary trust, one layer | 10 |
| Source of wealth | Sale of a business, documented | 12 |
| PEP exposure | None recorded | 20 |
| Delivery channel | Face to face | 3 |
| Sector | Private wealth | 5 |
Your categories, your weights, your triggers
A model is categories, factors and options. Each factor resolves from a fact on the file (jurisdiction, structure type, PEP flag, delivery channel) or from a choice an officer records. Raw points are weighted and capped, the caps sum to 100, then the total is banded and the automatic triggers applied, in that order and never another.
- Edited by your firm in Settings
- Default reproduces the six-factor GFSC split
- Triggers: sanctions candidate, confirmed PEP, high-risk jurisdiction
| Category | Weight | Cap | Factors |
|---|---|---|---|
| Jurisdiction | 1.5 | 25 | Residence, nationality, structure jurisdiction |
| Structure | 1.0 | 15 | Type, layers, nominees |
| Source of wealth | 1.2 | 20 | Clarity, documentation |
| PEP exposure | 2.0 | 20 | PEP, associate, former PEP |
| Delivery channel | 1.0 | 10 | Face to face, introduced, remote |
| Sector | 1.0 | 10 | Activity, cash intensity |
Sanctions candidate above threshold · PEP confirmed · High-risk jurisdiction on the GFSC list. A trigger sets the level to High and names itself on the breakdown; an override cannot bring it back below.
A score with its working
The rating shows the total, the level and every line that made it: the option chosen for each factor, its points and its weighted contribution. A trigger that raised the level says so. An officer can override upward with a reason; a trigger cannot be overridden downward.
- Line-by-line breakdown on the file
- Overrides recorded with a reason
- Rating and breakdown in the verification record
| Category | Option | Points | Weighted |
|---|---|---|---|
| Jurisdiction | Guernsey resident, GBR national | 4 | 6 |
| Structure | Discretionary trust, one layer | 6 | 6 |
| Source of wealth | Sale of business, documented | 5 | 6 |
| PEP exposure | Confirmed PEP, associate | 10 | 20 |
| Delivery channel | Face to face | 0 | 0 |
| Sector | Private wealth | 5 | 5 |
Reviews on the cadence the rating sets
Each level carries a review interval. The next review date follows from the last review and the current level, so a rating change moves the date. Due and overdue reviews sit on the dashboard, in the Monitoring tab and in the compliance monitoring programme's tests.
- Interval per level, set by the firm
- Due dates move with the rating
- Overdue counted by the monitoring programme
| File | Rating | Cadence | Due | Status |
|---|---|---|---|---|
| Vela Holdings Ltd | Medium | 12 months | Fri 26 Sep | Due |
| Ormer Family Trust | High | 6 months | Mar 2027 | Current |
| Vale Settlement | Low | 36 months | Sep 2029 | Current |
| Herm Holdings Ltd | Medium | 12 months | 2 Sep | Overdue |
The memo, drafted from what changed
When a review falls due, Flarion gathers what changed on the file since the last one: verifications, screening runs and decisions, documents, rating moves. It drafts a memo from that for the reviewer to edit, conclude and sign. The review record keeps the draft, the edits, the conclusion and the signature.
- Drafted from the file's own events
- Conclusion and signature required
- Every review kept, not overwritten
Passport for J. Brehaut renewed and re-verified 22 Sep. One adverse media result reviewed, not adverse. Screening clear at each weekly run; no new candidates. Source of wealth unchanged. Rating stays Medium; next review September 2027.
Draft assembled from the file. Edit, then sign.
The firm's own business risk assessment
Beside the client files, the firm's business risk assessment under Handbook Rule 3.33: inherent risk, controls and residual risk by area, reviewed against the current National Risk Assessment and approved by the board, with the approval on the record.
- Inherent, controls, residual by area
- Reviewed against the NRA
- Board approval recorded
| Area | Inherent | Controls | Residual |
|---|---|---|---|
| Customers | High | CDD on every party, PEP triggers | Medium |
| Jurisdictions | Medium | GFSC list, jurisdiction factor | Low |
| Products | Medium | Structure factor, source of wealth | Medium |
| Delivery | Low | Face to face, introducer register | Low |
Questions about risk and reviews
Is the risk model ours or Flarion's?
Yours. Categories, factors, weights, caps, the bands and the automatic high triggers are all edited by your firm in Settings. The default reproduces the six-factor GFSC split so a firm that never opens the editor sees a sensible model; the moment you change it, every file scores on yours.
Can an officer override a rating?
Up, always, with a reason. Down, only as far as the model allows: an automatic trigger sets the level to High and names itself on the breakdown, and no override brings the level back below it.
How is the review cadence set?
By the rating. Each level in your model carries a review interval, and the next review date follows from the last review and the current level. Change the level and the due date moves. Overdue reviews are on the dashboard and in the monitoring programme.
Who writes the review memo?
A person signs it. Flarion assembles what changed on the file since the last review, drafts the memo from that, and the reviewer edits it, records a conclusion and signs. The draft is an aid to reading; the judgement and the signature are the reviewer's.
Rate your own files in the demo.
Bring your risk methodology. We load it as the model and score your spreadsheet on it before the call ends.