Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations

FINANS TILSYNET
Postboks 1187 Sentrum
0107 Oslo
Circular
Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations CIRCULAR:
14/2019
DATE:
Published 23.12.2019. Corrected 20.01.2020.
THE CIRCULAR APPLIES TO:
Auditors
Audit Firms

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations 2 | Finanstilsynet Contents 1 Introduction 4
1.1 General 4
1.2 Scope of Application 4
2 Organization 5
2.1 Money Laundering Responsible Person 5
2.2 Training 6
2.3 Internal Control and Compliance Officer 7
3 Risk-based Approach, Risk Assessment and Procedures 7
3.1 Risk-based Approach 7
3.2 Firm-level Risk Assessment 8
3.2.1 Introduction 8
3.2.2 Details on Content 9
3.3 Procedures 13
3.3.1 Requirements for the Audit Firm's Money Laundering Procedures 13
3.3.2 Content of the Procedures 13
4 Customer Due Diligence 16
4.1 Duty to Conduct Customer Due Diligence 16
4.2 Purpose and Intended Nature of the Customer Relationship 16
4.3 Duty to Make Copies and Verify Correct Copies of Identification Documents 17
4.4 Verification of Identity – Legal Persons 17
4.4.1 Lookup in or Printout from Register or Company Certificate 17
4.4.2 Requirements for Organization Number and Registration Duty 18
4.4.3 Natural Persons Acting on Behalf of the Customer 18
4.5 Verification of Identity – Natural Persons 18
4.5.1 General 19
4.5.1.1 Identification Documents 19
4.5.1.2 Electronic Identification 19
4.5.1.3 Verification of Identity without Personal Appearance 19
4.5.2 Persons Acting on Behalf of the Customer 20
4.5.2.1 Verification of Identity 20
4.5.2.2 Verification of Right to Act on Behalf of the Customer 20
4.5.3 Verification of Identity when the Customer is a Natural Person 21
4.6 Verification of Identity – Ultimate Beneficial Owners 21
4.6.1 Purpose 21
4.6.2 Identification and Verification 21
4.6.3 Understanding the Customer's Ownership and Control Structure 22
4.6.4 Documentation 22
4.7 Simplified Customer Due Diligence 22
4.8 Enhanced Customer Due Diligence 23
4.8.1 Risk Factors 23
4.8.2 Which Measures Should Be Carried Out? 23
4.8.3 Customer Due Diligence towards Customers Who Are Themselves Reporting Entities 24
4.9 Enhanced Customer Due Diligence – Politically Exposed Persons (PEPs) 24
4.10 Ongoing Monitoring 25
4.11 Customer Due Diligence Performed by Third Parties 26
5 Rejection and Termination of Customer Relationships 26

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations Finanstilsynet | 3 6 Investigation and Reporting 27
6.1 Duty to Investigate 27
6.2 Duty to Report 28
6.3 Prohibition on Disclosure (Tipping Off) 29
6.3.1 General Principle 29
6.3.2 Exceptions 30
7 Requirements for Systems Enabling Rapid and Complete Responses to Authorities 30 8 Processing of Information 31 9 Good Audit Practice when the Customer is a Reporting Entity under the Money Laundering Act 31 Editorial Note 20.01.2020:
Finanstilsynet has made certain minor corrections to this circular:
These are in section 4.4.3 (page 18), in 4.5.1.1 (page 19), in 4.5.2 (in the heading on page 20), in 4.5.2.1 (page 20) and in 4.7 (page 23).

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations 4 | Finanstilsynet 1 Introduction
1.1 General
Services offered by auditors are suitable for preventing and detecting all involvement with proceeds of crime (money laundering) and financing of terrorist activities, terrorist organizations or individual terrorists (terrorist financing). Audit firms and auditors who conduct audit activities in sole proprietorships (both referred to as audit firms) therefore play an important role in protecting the financial and economic system and society as a whole. This circular is intended as guidance to help understand the obligations that an audit firm and those who perform work for the audit firm have under the Money Laundering Act. The circular also contains a more detailed description of what follows from good audit practice according to the Auditors Act § 5-2 second paragraph when the customer is a reporting entity. The circular replaces circular 3/2017. The guidance does not provide a complete overview of all obligations under the Money Laundering Act. When it comes to a closer interpretation of how certain provisions are to be understood, reference is made to Finanstilsynet's general guidance to the Money Laundering Act – circular 8/2019. 1 The obligations under the Money Laundering Act also apply to existing customer relationships that were entered into before the law came into force.
1.2 Scope of Application
The Money Laundering Act applies to audit firms and auditors in the exercise of their profession. This means that all audit firms are covered by the law. Auditors who are employed in other businesses are not covered by the law. Several of the obligations under the Money Laundering Act apply to the audit firm (at "firm level"). Reference is made in particular to the requirement for firm-level risk assessment, establishment of internal procedures, appointment of a money laundering responsible person and training. Other obligations must be fulfilled by the person responsible for the assignment on behalf of the firm (at "assignment level"). This applies, for example, to the implementation of risk classification of the current customer and the implementation of initial customer due diligence and ongoing monitoring. It is also the person responsible for the assignment and the employees who must investigate further matters that may indicate that the customer is involved in money laundering or terrorist financing. It is the audit firm that must report to Økokrim (the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime). Finanstilsynet assumes that all services where an approved auditor is responsible for the execution of the assignment on behalf of the audit firm will be covered by the Money Laundering Act. Also services that are performed by others than approved auditors on behalf of the audit firm will be covered by the law when the service is a natural part of the business in an audit firm. 1 https://www.finanstilsynet.no/nyhetsarkiv/rundskriv/2019/veileder-til-hvitvaskingsloven/

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations Finanstilsynet | 5 Examples of such services are:

• tax advice
• execution of due diligence assignments in connection with acquisitions and mergers
• transaction advisory
• corporate advisory
• investment advisory
  If the audit firm offers business services, the services are regardless subject to the money laundering regulations on this basis. See more about this in the Money Laundering Act §§ 2 letter j), 4 second paragraph letter a) and § 42 and information on Finanstilsynet's website, 2 which deal with business services. 2 Organization
  2.1 Money Laundering Responsible Person
  A money laundering responsible person must be appointed, cf. Money Laundering Act § 8 fifth paragraph, who shall:
• be a person in management
• have sufficient experience, competence and ability to make decisions
  related to the firm's measures against the risk of money laundering and terrorist financing
• have a special responsibility for developing and following up money laundering procedures, including that
  the procedures are complied with in the firm
• have the overall responsibility that matters that may indicate money laundering or
  terrorist financing are investigated and that information on suspicious matters is eventually forwarded to Økokrim
• be a resource and contact person for the firm and its employees on
  the money laundering area
  The appointment of a money laundering responsible person does not exempt the audit firm's management from the responsibility they have for the business under general company law, including the responsibility for compliance with the Money Laundering Act. In smaller audit firms, Finanstilsynet assumes that the money laundering responsible person must be a person in the top management, i.e. the managing director or a board member. In sole proprietorships, the owner will be the money laundering responsible person. If the money laundering responsible person does not belong to the top management, the firm must justify why another solution has been chosen. The justification must be reasonable and can be documented. The money laundering responsible person cannot be the same person as a possible compliance officer, see section 2.3. The money laundering responsible person can delegate work tasks to others in the firm, but cannot delegate the responsibility that the money laundering responsible person has under the Money Laundering Act. 2 https://www.finanstilsynet.no/konsesjon/tilbyder-av-virksomhetstjenester/

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations 6 | Finanstilsynet If a risk assessment of the scope and nature of the business suggests it, cf. section 3.2.2 below, the suitability of the money laundering responsible person must be assessed, cf. Money Laundering Act § 35 second paragraph letter b). In these cases, as a minimum, the money laundering responsible person's competence, experience and personal suitability must be assessed. It is not necessary to obtain a police certificate. Regarding the money laundering responsible person in a group context, see section 3.2.2 in Finanstilsynet's general guidance to the Money Laundering Act (circular 8/2019).
2.2 Training
The audit firm is obliged to ensure that employees and others who perform assignments for the firm are given sufficient training, cf. Money Laundering Act § 36. What is sufficient will depend on which services the audit firm offers, the size of the firm and the risk that the firm can be used as part of money laundering and terrorist financing. The individual employee's role, responsibility and tasks will have significance for what training is considered sufficient. The training program must always be up to date. The training must be given so that employees and others who perform assignments for the firm are familiar with the firm's risk exposure and obligations under the Money Laundering Act, and that they are enabled to recognize matters that may indicate money laundering and terrorist financing. As a minimum, the audit firm must give employees training in:

• What money laundering and terrorist financing are
  It is absolutely fundamental that each employee has good knowledge of what money laundering and terrorist financing are. Without knowledge of money laundering and terrorist financing, it will be difficult for the individual employee to detect matters that may indicate that funds are linked to money laundering or terrorist financing.
• Knowledge of own firm – including possible vulnerabilities of the firm
  Employees must have good knowledge of why the audit firm can be vulnerable to being used as part of money laundering or terrorist financing. Examples can be the way the audit firm is organized, different technological systems used, that some services delivered are more susceptible to being used as part of money laundering or terrorist financing, and that the firm has outsourced parts of the money laundering work.
• Knowledge of the type of customers the firm has – possible threats to the firm
  Each employee must further be aware of the threats that can be directed against the audit firm, including in particular which types of customers, including PEPs (politically exposed person), that the auditor must have extra attention directed towards. The audit firm must provide training in indicator lists and characteristics that are relevant for the employees. The training must be updated as criminal trends change. The National Intelligence Service (NTAES) has prepared a list of "Indicators of Suspicious Transactions for Reporting Entities within accounting and auditing". It can also be other relevant indicator lists. The list is available for logged-in members on the Norwegian Association of Certified Public Accountants' website. 3

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations Finanstilsynet | 7

• Auditor's obligations under the Money Laundering Act
  Each employee must be aware of the obligations under the money laundering regulations. The firm's procedures will be indicative of which topics are relevant. Training must be given to all new employees and regularly to all employees, so that necessary knowledge is maintained. Training does not necessarily have to take place annually, unless the training program is updated. How often training should take place for each employee etc. also depends on their responsibility and role in the audit firm. For example, the persons who are affected by changes in a money laundering procedure must be given new training. Also the firm's board and management must have training that reflects their role and responsibility for the firm's compliance with the money laundering regulations. The firm must be able to document that the training obligations have been fulfilled.
  2.3 Internal Control and Compliance Officer
  The audit firm must ensure through internal control in the business that the money laundering regulations are observed, cf. Money Laundering Act § 35 second paragraph. A corresponding obligation follows from ISQC-1 point 48. See more about the requirement for internal control in section 3.3.2. If the nature and scope of the firm suggest it, a compliance officer must be appointed. This must be decided based on a concrete assessment. Finanstilsynet assumes that it is only in the largest audit firms that it is necessary to assess the need to appoint a compliance officer. 3 Risk-based Approach, Risk Assessment and Procedures
  3.1 Risk-based Approach
  The audit firm must have a risk-based approach in the development of firm-level risk assessment, procedures and in customer due diligence. It is not possible to deviate from the regulations even if the risk is assessed as low, but low risk can be of significance for which measures must be implemented. 3 https://www.revisorforeningen.no/

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations 8 | Finanstilsynet
3.2 Firm-level Risk Assessment
3.2.1 Introduction
All audit firms must make an overall risk assessment, cf. Money Laundering Act § 7. It is the audit firm's own risk profile that must be mapped. Even if templates for risk assessments prepared by industry associations and others are used, these must be adapted to the individual audit firm. The risk assessment must be documented. The firm-level risk assessment is important because it forms the basis for which procedures are established in the firm. The procedures are again important for implementing measures to counter the risk and ensure that the audit firm's work against money laundering and terrorist financing is organized responsibly, and that there is sufficient attention directed towards this work in the execution of the individual assignments. Furthermore, the firm-level risk assessment forms the starting point for the risk classification of the individual customer. This is necessary to determine whether the customer should be subject to enhanced customer due diligence, and which risk-reducing measures must be implemented. A thorough firm-level risk analysis is important for the firm's resources to be allocated to the areas where the money laundering and terrorist financing risk is highest. The firm-level risk assessment consists of identifying and understanding threats against the audit firm (external factors) and vulnerabilities in the firm (internal factors), and the significance of these. The scope of the risk assessment will vary depending on the size, risk exposure and complexity of the audit firm, cf. Money Laundering Act § 7 fourth paragraph. For smaller audit firms with a simple and clear service offer and customer segment, the risk assessment can be less comprehensive, but can never be omitted. Larger audit firms that offer many different services to different customer groups, with exposure to different risk-prone industries and geographical areas, will have to make more comprehensive risk assessments. Most firms will have a customer portfolio where some customers pose a higher risk that the audit firm is used as part of money laundering or terrorist financing than others. One of the purposes of the risk assessment is to have a good overall overview of the risk in the portfolio. This means that the audit firm must identify customers with a higher risk to ensure that these can be subjected to a stronger control regime. This will put the firm better in a position to prioritize customer due diligence, and can reveal possible money laundering or terrorist financing. The risk assessment must be updated regularly. A renewed assessment must be made annually, possibly more frequently if necessary. The need to update the risk assessment may arise in the following cases:

• the audit firm launches new services
• there is new knowledge about methods and trends for money laundering and
  terrorist financing that are used by criminals
• the audit firm's accumulated knowledge and experience suggest a need for updating
• the money laundering regulations change
  The risk assessment and changes to it must be documented. The overall risk assessment must be set by the audit firm's top management, which is the board and the managing director.

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations Finanstilsynet | 9
3.2.2 Details on Content
The audit firm must have knowledge of what money laundering and terrorist financing are. Without knowledge of money laundering and terrorist financing it will not be possible to assess the risk that own firm can be misused by criminals for these purposes. As a minimum, all audit firms must have a risk assessment that covers the points in the Money Laundering Act § 7 second paragraph, letter a) to d). Internal Factors The risk assessment must reflect internal factors in the audit firm that make the audit firm vulnerable to being exploited as part of money laundering and terrorist financing. Own business, including the nature and scope of the business – letter a) The following factors regarding own firm can be a vulnerability that increases the risk of being used as part of money laundering or terrorist financing:

• Number of employees and competence level of these, organization and turnover. New employees or
  employees with a low competence level can be a vulnerability that requires increased follow-up and training. The same applies the larger the firm is. For example, branch offices spread over a larger geographical area can mean vulnerability for lack of follow-up, coordination and training.
• Use of technology. Technology can be deficient, for example electronic
  systems that contain checklists for acceptance of customer relationships can contain deficiencies or incorrect programming. Also new technology that is put into use must be assessed against the money laundering regulations.
• Outsourcing. Outsourcing entails vulnerability because the contracting party is not
  necessarily familiar with, or has attention directed towards, the money laundering regulations. It is the audit firm that is responsible for ensuring that the obligations under the Money Laundering Act are observed. The audit firm must therefore assess whether the persons or companies that it has outsourced tasks to, have sufficient knowledge and competence to fulfill the obligations in the money laundering regulations for the assignments that are outsourced.
• Closeness to the customer. If there is a closeness to or dependence on customers, this can
  increase the vulnerability that the auditor does not carry out all mandatory customer due diligence. A closeness that can make the firm vulnerable is, for example, that the business is operated in a small place where the customer, or persons who act on behalf of the customer, are known, either as a result of collaboration, or in a private context. A limited customer selection can also be a vulnerability because it can mean that not all mandatory customer due diligence is carried out due to fear of losing income. Firm's products, services and customer relationships – letter b) The vulnerability to being exploited as part of money laundering and terrorist financing will vary depending on which services are delivered. The audit firm must therefore identify and assess which factors regarding the individual services offered, can make the firm vulnerable to being used as part of money laundering or terrorist financing.

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations 10 | Finanstilsynet The audit firm must have an overview of all services that it delivers, and an understanding of which customers are covered by the Money Laundering Act, cf. above in section 1.2. The firm must assess how the individual service delivered can be vulnerable to being used as part of money laundering or terrorist financing. For new services, the risk assessment must be made before they are launched. The following services are examples that can constitute a vulnerability that increases the risk that the audit firm can be used as part of money laundering or terrorist financing:

• Annual financial statement audit. The auditor is the public's person of trust in the execution of
  the annual financial statement audit. The fact that a customer is audited contributes to the public's trust in the customer's annual accounts, and can mean that control measures, for example book audits, from the public side are prioritized lower. If a customer who is not subject to audit duty nevertheless chooses to have an auditor, the auditor must assess the purpose of the customer relationship and intended nature, cf. Money Laundering Act § 13 fifth paragraph. In auditing companies that handle others' funds, for example client funds, or where payment flows go through the company, the auditor must be aware that the customer can be used by third parties as part of money laundering or terrorist financing.
• Attestation services and related services. The auditor's attestations and statements can
  contribute to legitimizing the matter in question, and in this way camouflage money laundering or terrorist financing. For example, the auditor's statements about capital increase after company law legislation can give trust that the origin of the funds is legitimate. In non-mandatory attestation services, the auditor must assess the purpose of the customer relationship and intended nature, cf. Money Laundering Act § 13 fifth paragraph.
• Advisory. Investment advice and tax advice related to complicated
  customer structures and products linked to several countries can contribute to obscuring and integrating money laundering of funds. External Factors The risk assessment must reflect external factors that pose threats that the audit firm can be exploited as part of money laundering and terrorist financing. This means that the audit firm must know its clients. Type of customers and customer groups – letter c)
• Natural persons
  The category includes several groups, e.g. Norwegian citizens, foreign citizens, incapacitated persons etc. Increased threat can exist alone or in combination with other factors, including that the person is a politically exposed person (PEP), comes from, or is resides abroad, is a known criminal, has connections to tax havens or uses attorneys.

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations Finanstilsynet | 11

• Politically Exposed Persons – PEP
  The customer, the person who acts on behalf of the customer, or the ultimate beneficial owner, is a politically exposed person. The category also includes close family members4 and known associates5 to a politically exposed person. The threat is linked to money laundering of proceeds from corruption.
• Ultimate Beneficial Owners
  If the ultimate beneficial owners of the customer turn out to be established in high-risk countries, it requires particular attention from the auditor. Reference is made to Finanstilsynet's overview of high-risk countries. 6
• Persons listed on sanctions lists
  Customers, persons who represent customers or ultimate beneficial owners who are on the UN or EU lists of persons or organizations suspected of participating in terrorist financing, can pose a threat to the audit firm, see the Ministry of Foreign Affairs' "freezing guide".7
• Criminal persons linked to customers
  Central persons in the management of the customer or ultimate beneficial owners have a criminal background, are members of a group that engages in crime or are close relatives of criminals, can pose a threat. The threat can e.g. be linked to unclearness at the origin of the funds.
• Customers with ties to terrorist organizations
  The risk of being used

4 https://www.regjeringen.no/no/dokumenter/veiledning-om-hvitvaskingsloven/id2589797/ 5 https://www.regjeringen.no/no/dokumenter/veiledning-om-hvitvaskingsloven/id2589797/ 6 https://www.finanstilsynet.no/tema/hvitvasking/hoeyrisikoland/ 7 https://www.regjeringen.no/no/dokumenter/frysveileder/id2589797/

Guidance on Auditors and Audit Firms' Compliance with the Money Laundering Regulations 12 | Finanstilsynet to be used as part of money laundering or terrorist financing is high. The audit firm must have procedures for how to handle such customers.

• Customers in high-risk countries
  Customers established in countries that Finanstilsynet has identified as high-risk countries pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers in countries with weak anti-money laundering controls
  Customers established in countries with weak anti-money laundering controls pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with complex ownership structures
  Customers with complex ownership structures pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with cash-intensive businesses
  Customers with cash-intensive businesses pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with unusual transaction patterns
  Customers with unusual transaction patterns pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear business purpose
  Customers with no clear business purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no physical presence
  Customers with no physical presence pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear economic purpose
  Customers with no clear economic purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear legal purpose
  Customers with no clear legal purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear social purpose
  Customers with no clear social purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear environmental purpose
  Customers with no clear environmental purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear political purpose
  Customers with no clear political purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear cultural purpose
  Customers with no clear cultural purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear educational purpose
  Customers with no clear educational purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear religious purpose
  Customers with no clear religious purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear charitable purpose
  Customers with no clear charitable purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear scientific purpose
  Customers with no clear scientific purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear artistic purpose
  Customers with no clear artistic purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear sporting purpose
  Customers with no clear sporting purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear recreational purpose
  Customers with no clear recreational purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear entertainment purpose
  Customers with no clear entertainment purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear media purpose
  Customers with no clear media purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear technology purpose
  Customers with no clear technology purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear health purpose
  Customers with no clear health purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear legal purpose
  Customers with no clear legal purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear financial purpose
  Customers with no clear financial purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear insurance purpose
  Customers with no clear insurance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear banking purpose
  Customers with no clear banking purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear investment purpose
  Customers with no clear investment purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear trading purpose
  Customers with no clear trading purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear manufacturing purpose
  Customers with no clear manufacturing purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear construction purpose
  Customers with no clear construction purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear transportation purpose
  Customers with no clear transportation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear logistics purpose
  Customers with no clear logistics purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear retail purpose
  Customers with no clear retail purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear wholesale purpose
  Customers with no clear wholesale purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear hospitality purpose
  Customers with no clear hospitality purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear tourism purpose
  Customers with no clear tourism purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear real estate purpose
  Customers with no clear real estate purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear agriculture purpose
  Customers with no clear agriculture purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear forestry purpose
  Customers with no clear forestry purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear fishing purpose
  Customers with no clear fishing purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear mining purpose
  Customers with no clear mining purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear energy purpose
  Customers with no clear energy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear utility purpose
  Customers with no clear utility purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear telecommunications purpose
  Customers with no clear telecommunications purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear broadcasting purpose
  Customers with no clear broadcasting purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear publishing purpose
  Customers with no clear publishing purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear printing purpose
  Customers with no clear printing purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear packaging purpose
  Customers with no clear packaging purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear labeling purpose
  Customers with no clear labeling purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear advertising purpose
  Customers with no clear advertising purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear marketing purpose
  Customers with no clear marketing purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear public relations purpose
  Customers with no clear public relations purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear event management purpose
  Customers with no clear event management purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear conference purpose
  Customers with no clear conference purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear exhibition purpose
  Customers with no clear exhibition purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear fair purpose
  Customers with no clear fair purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear festival purpose
  Customers with no clear festival purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear concert purpose
  Customers with no clear concert purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear theater purpose
  Customers with no clear theater purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear cinema purpose
  Customers with no clear cinema purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear museum purpose
  Customers with no clear museum purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear gallery purpose
  Customers with no clear gallery purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear library purpose
  Customers with no clear library purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear archive purpose
  Customers with no clear archive purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear research purpose
  Customers with no clear research purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear development purpose
  Customers with no clear development purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear innovation purpose
  Customers with no clear innovation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear design purpose
  Customers with no clear design purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear architecture purpose
  Customers with no clear architecture purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear engineering purpose
  Customers with no clear engineering purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear surveying purpose
  Customers with no clear surveying purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear mapping purpose
  Customers with no clear mapping purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear geodesy purpose
  Customers with no clear geodesy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear meteorology purpose
  Customers with no clear meteorology purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear oceanography purpose
  Customers with no clear oceanography purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear geology purpose
  Customers with no clear geology purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear paleontology purpose
  Customers with no clear paleontology purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear archaeology purpose
  Customers with no clear archaeology purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear anthropology purpose
  Customers with no clear anthropology purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear sociology purpose
  Customers with no clear sociology purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear psychology purpose
  Customers with no clear psychology purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear psychiatry purpose
  Customers with no clear psychiatry purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear social work purpose
  Customers with no clear social work purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear counseling purpose
  Customers with no clear counseling purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear coaching purpose
  Customers with no clear coaching purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear mentoring purpose
  Customers with no clear mentoring purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear tutoring purpose
  Customers with no clear tutoring purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear teaching purpose
  Customers with no clear teaching purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear learning purpose
  Customers with no clear learning purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear education purpose
  Customers with no clear education purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear training purpose
  Customers with no clear training purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear development purpose
  Customers with no clear development purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear growth purpose
  Customers with no clear growth purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear expansion purpose
  Customers with no clear expansion purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear scaling purpose
  Customers with no clear scaling purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear optimization purpose
  Customers with no clear optimization purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear improvement purpose
  Customers with no clear improvement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear enhancement purpose
  Customers with no clear enhancement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear upgrade purpose
  Customers with no clear upgrade purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear update purpose
  Customers with no clear update purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear refresh purpose
  Customers with no clear refresh purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear renewal purpose
  Customers with no clear renewal purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear restoration purpose
  Customers with no clear restoration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear repair purpose
  Customers with no clear repair purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear maintenance purpose
  Customers with no clear maintenance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear support purpose
  Customers with no clear support purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear assistance purpose
  Customers with no clear assistance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear help purpose
  Customers with no clear help purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear aid purpose
  Customers with no clear aid purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear relief purpose
  Customers with no clear relief purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear rescue purpose
  Customers with no clear rescue purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear salvation purpose
  Customers with no clear salvation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear deliverance purpose
  Customers with no clear deliverance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear liberation purpose
  Customers with no clear liberation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear freedom purpose
  Customers with no clear freedom purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear independence purpose
  Customers with no clear independence purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear autonomy purpose
  Customers with no clear autonomy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear sovereignty purpose
  Customers with no clear sovereignty purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-determination purpose
  Customers with no clear self-determination purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-governance purpose
  Customers with no clear self-governance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-rule purpose
  Customers with no clear self-rule purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-management purpose
  Customers with no clear self-management purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-control purpose
  Customers with no clear self-control purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-regulation purpose
  Customers with no clear self-regulation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-discipline purpose
  Customers with no clear self-discipline purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-restraint purpose
  Customers with no clear self-restraint purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-denial purpose
  Customers with no clear self-denial purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-sacrifice purpose
  Customers with no clear self-sacrifice purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear selflessness purpose
  Customers with no clear selflessness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear altruism purpose
  Customers with no clear altruism purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear benevolence purpose
  Customers with no clear benevolence purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear kindness purpose
  Customers with no clear kindness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear compassion purpose
  Customers with no clear compassion purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear empathy purpose
  Customers with no clear empathy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear sympathy purpose
  Customers with no clear sympathy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear understanding purpose
  Customers with no clear understanding purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear tolerance purpose
  Customers with no clear tolerance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear acceptance purpose
  Customers with no clear acceptance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear inclusion purpose
  Customers with no clear inclusion purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear integration purpose
  Customers with no clear integration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear unity purpose
  Customers with no clear unity purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear harmony purpose
  Customers with no clear harmony purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear peace purpose
  Customers with no clear peace purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear tranquility purpose
  Customers with no clear tranquility purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear calmness purpose
  Customers with no clear calmness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear serenity purpose
  Customers with no clear serenity purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear quietness purpose
  Customers with no clear quietness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear silence purpose
  Customers with no clear silence purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear stillness purpose
  Customers with no clear stillness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear rest purpose
  Customers with no clear rest purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear relaxation purpose
  Customers with no clear relaxation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear recreation purpose
  Customers with no clear recreation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear leisure purpose
  Customers with no clear leisure purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear enjoyment purpose
  Customers with no clear enjoyment purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear pleasure purpose
  Customers with no clear pleasure purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear delight purpose
  Customers with no clear delight purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear joy purpose
  Customers with no clear joy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear happiness purpose
  Customers with no clear happiness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear bliss purpose
  Customers with no clear bliss purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear ecstasy purpose
  Customers with no clear ecstasy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear euphoria purpose
  Customers with no clear euphoria purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear exhilaration purpose
  Customers with no clear exhilaration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear excitement purpose
  Customers with no clear excitement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear thrill purpose
  Customers with no clear thrill purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear adventure purpose
  Customers with no clear adventure purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear exploration purpose
  Customers with no clear exploration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear discovery purpose
  Customers with no clear discovery purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear invention purpose
  Customers with no clear invention purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear creation purpose
  Customers with no clear creation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear production purpose
  Customers with no clear production purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear generation purpose
  Customers with no clear generation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear formation purpose
  Customers with no clear formation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear development purpose
  Customers with no clear development purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear evolution purpose
  Customers with no clear evolution purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear progress purpose
  Customers with no clear progress purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear advancement purpose
  Customers with no clear advancement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear improvement purpose
  Customers with no clear improvement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear enhancement purpose
  Customers with no clear enhancement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear upgrade purpose
  Customers with no clear upgrade purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear update purpose
  Customers with no clear update purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear refresh purpose
  Customers with no clear refresh purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear renewal purpose
  Customers with no clear renewal purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear restoration purpose
  Customers with no clear restoration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear repair purpose
  Customers with no clear repair purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear maintenance purpose
  Customers with no clear maintenance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear support purpose
  Customers with no clear support purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear assistance purpose
  Customers with no clear assistance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear help purpose
  Customers with no clear help purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear aid purpose
  Customers with no clear aid purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear relief purpose
  Customers with no clear relief purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear rescue purpose
  Customers with no clear rescue purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear salvation purpose
  Customers with no clear salvation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear deliverance purpose
  Customers with no clear deliverance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear liberation purpose
  Customers with no clear liberation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear freedom purpose
  Customers with no clear freedom purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear independence purpose
  Customers with no clear independence purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear autonomy purpose
  Customers with no clear autonomy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear sovereignty purpose
  Customers with no clear sovereignty purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-determination purpose
  Customers with no clear self-determination purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-governance purpose
  Customers with no clear self-governance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-rule purpose
  Customers with no clear self-rule purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-management purpose
  Customers with no clear self-management purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-control purpose
  Customers with no clear self-control purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-regulation purpose
  Customers with no clear self-regulation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-discipline purpose
  Customers with no clear self-discipline purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-restraint purpose
  Customers with no clear self-restraint purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-denial purpose
  Customers with no clear self-denial purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-sacrifice purpose
  Customers with no clear self-sacrifice purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear selflessness purpose
  Customers with no clear selflessness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear altruism purpose
  Customers with no clear altruism purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear benevolence purpose
  Customers with no clear benevolence purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear kindness purpose
  Customers with no clear kindness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear compassion purpose
  Customers with no clear compassion purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear empathy purpose
  Customers with no clear empathy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear sympathy purpose
  Customers with no clear sympathy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear understanding purpose
  Customers with no clear understanding purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear tolerance purpose
  Customers with no clear tolerance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear acceptance purpose
  Customers with no clear acceptance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear inclusion purpose
  Customers with no clear inclusion purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear integration purpose
  Customers with no clear integration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear unity purpose
  Customers with no clear unity purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear harmony purpose
  Customers with no clear harmony purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear peace purpose
  Customers with no clear peace purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear tranquility purpose
  Customers with no clear tranquility purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear calmness purpose
  Customers with no clear calmness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear serenity purpose
  Customers with no clear serenity purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear quietness purpose
  Customers with no clear quietness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear silence purpose
  Customers with no clear silence purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear stillness purpose
  Customers with no clear stillness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear rest purpose
  Customers with no clear rest purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear relaxation purpose
  Customers with no clear relaxation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear recreation purpose
  Customers with no clear recreation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear leisure purpose
  Customers with no clear leisure purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear enjoyment purpose
  Customers with no clear enjoyment purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear pleasure purpose
  Customers with no clear pleasure purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear delight purpose
  Customers with no clear delight purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear joy purpose
  Customers with no clear joy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear happiness purpose
  Customers with no clear happiness purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear bliss purpose
  Customers with no clear bliss purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear ecstasy purpose
  Customers with no clear ecstasy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear euphoria purpose
  Customers with no clear euphoria purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear exhilaration purpose
  Customers with no clear exhilaration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear excitement purpose
  Customers with no clear excitement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear thrill purpose
  Customers with no clear thrill purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear adventure purpose
  Customers with no clear adventure purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear exploration purpose
  Customers with no clear exploration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear discovery purpose
  Customers with no clear discovery purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear invention purpose
  Customers with no clear invention purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear creation purpose
  Customers with no clear creation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear production purpose
  Customers with no clear production purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear generation purpose
  Customers with no clear generation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear formation purpose
  Customers with no clear formation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear development purpose
  Customers with no clear development purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear evolution purpose
  Customers with no clear evolution purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear progress purpose
  Customers with no clear progress purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear advancement purpose
  Customers with no clear advancement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear improvement purpose
  Customers with no clear improvement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear enhancement purpose
  Customers with no clear enhancement purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear upgrade purpose
  Customers with no clear upgrade purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear update purpose
  Customers with no clear update purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear refresh purpose
  Customers with no clear refresh purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear renewal purpose
  Customers with no clear renewal purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear restoration purpose
  Customers with no clear restoration purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear repair purpose
  Customers with no clear repair purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear maintenance purpose
  Customers with no clear maintenance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear support purpose
  Customers with no clear support purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear assistance purpose
  Customers with no clear assistance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear help purpose
  Customers with no clear help purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear aid purpose
  Customers with no clear aid purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear relief purpose
  Customers with no clear relief purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear rescue purpose
  Customers with no clear rescue purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear salvation purpose
  Customers with no clear salvation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear deliverance purpose
  Customers with no clear deliverance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear liberation purpose
  Customers with no clear liberation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear freedom purpose
  Customers with no clear freedom purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear independence purpose
  Customers with no clear independence purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear autonomy purpose
  Customers with no clear autonomy purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear sovereignty purpose
  Customers with no clear sovereignty purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-determination purpose
  Customers with no clear self-determination purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-governance purpose
  Customers with no clear self-governance purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-rule purpose
  Customers with no clear self-rule purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-management purpose
  Customers with no clear self-management purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-control purpose
  Customers with no clear self-control purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-regulation purpose
  Customers with no clear self-regulation purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-discipline purpose
  Customers with no clear self-discipline purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-restraint purpose
  Customers with no clear self-restraint purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers with no clear self-denial purpose
  Customers with no clear self-denial purpose pose a higher risk. The audit firm must have procedures for how to handle such customers.
• Customers